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Build your defense before the interview. Tell us where your case stands and we will confirm your exposure, identify who is genuinely at risk, and tell you what to do before the Form 4180 interview.
Survives the business. Survives bankruptcy. Direct CPA representation from interview through appeal.
Most tax problems stay with the entity. A corporation owes a balance, pays or disputes it, and the owners move on. The trust fund recovery penalty does not work that way.
When a business withholds income tax, Social Security, and Medicare from paychecks but never sends it to the IRS, that money was held in trust. It belonged to the employees and the Treasury. The penalty is 100 percent of the unpaid trust fund taxes, assessed personally, and it does not go away when the business closes, restructures, or files for bankruptcy.
Four defenses, each technical and time-bound. Most cases combine more than one.
Show the person lacked real authority — using job descriptions, signature cards, board minutes, and the actual mechanics of who approved disbursements. Title is not the test; control is.
Reasonable delegation to a competent professional, with active monitoring, is a defense. Blind delegation is not. The line is whether the person knew, or should have known, that the taxes were not being paid.
Designate partial payments toward trust fund taxes so they reduce the personal exposure. Without designation, the IRS applies payments to the non-trust portion first, leaving the personal liability intact.
If the employment tax assessment itself is wrong, the error flows into the trust fund number. Sometimes the strongest case is upstream of the responsibility analysis.
We pull IRS transcripts, confirm the trust fund amount separately from the employer share, and identify who is genuinely at risk before anyone walks into an interview.
We represent you through the Form 4180 interview, where the IRS decides who had authority. When Letter 1153 issues, we use the 60-day appeal window — that is where the defense is built.
We assemble the responsibility, willfulness, allocation, or liability arguments that fit the facts; carry the appeal; and coordinate any payment arrangement with the broader resolution.
Why Businesses Trust Dimov Tax
CPA-led representation, licensed to stand in front of the IRS on your behalf — not advice from the sidelines.
Trust fund recovery penalty work is priced by scope, not a flat rate. The main factors are how far the investigation has progressed, the number of individuals potentially assessed, whether the case is at interview, appeal, or post-assessment, and whether business resolution and personal defense are both in play.
We scope the work to where the case stands and quote it directly. If an investigation has begun, act before the Form 4180 interview, not after. Once an assessment issues, the options narrow.
A common misconception is that bankruptcy ends the penalty. It does not. A business bankruptcy halts collection against the company but not the IRS's ability to assess and collect the trust fund penalty from individuals. It was built to survive the entity's dissolution.
Personal bankruptcy rarely helps either, since these penalties are generally nondischargeable — in the same category as fraud penalties. The trust fund recovery penalty is one of the few IRS tools that can follow a person out of a failed business and into their next one.
Source: Internal Revenue Code §6672; IRS Form 4180 and Letter 1153 procedures
A good fit if you:
If an investigation has begun, act before the Form 4180 interview, not after. This pairs naturally with our payroll tax compliance and any payroll tax resolution in motion.
Talk to Dimov Tax about your payroll tax history, who had financial authority, and where the exposure sits. The time to handle payroll tax exposure is before the letter arrives, but if it has already arrived, the next move still matters.
Confidential, no obligation. A CPA can stand in front of the IRS on your behalf.
