Enrolled Agent Exam [Part 3] 65, Trust Fund Recovery Penalty Representation

This podcast is made by Ran Chen, who holds an EA license, Insurance and Securities licenses (Series 6, 63, 65), and the CFP® designation. He is passionate about opening access to high-quality exam preparation resources and helping learners prepare more effectively for professional certification exams.

In this episode you will learn:

- The Trust Fund Recovery Penalty (TFRP) is a personal assessment against individuals for unpaid payroll taxes, not a business liability.

- Liability hinges on two standards: being a "responsible person" with significant financial control and "willfully" failing to pay the taxes.

- Willfulness does not require malicious intent; consciously paying other creditors before the IRS is sufficient to meet the standard.

- Upon receiving Letter 1153, the proposed assessment, a taxpayer has a critical 60-day window to file a protest with IRS Appeals.

- The IRS can assess the full penalty against multiple individuals, but is restricted to collecting the total unpaid tax amount only once.

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