DiscoverTax Defense Attorneys PodcastThe Trust Fund Recovery Penalty: What Business Owners Must Know
The Trust Fund Recovery Penalty: What Business Owners Must Know

The Trust Fund Recovery Penalty: What Business Owners Must Know

Update: 2025-08-11
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Episode Summary

Attorney Juda Gabaie discusses the Trust Fund Recovery Penalty (TFRP), a severe IRS penalty targeting business owners and employees for unpaid payroll and sales taxes in California. The episode explores the criteria for TFRP liability, including responsibility and willfulness, and the IRS’s investigative process, which may target non-executive roles like bookkeepers or receptionists. It highlights proactive strategies, such as using reputable payroll services and maintaining clear records, to avoid personal liability, emphasizing the critical role of tax defense attorneys in mitigating risks.


Key Timestamps

00:00 - Show Introduction and Welcome


01:30 - Understanding the Trust Fund Recovery Penalty


05:00 - Why TFRP Is a Serious Issue


09:00 - IRS Investigation Process for TFRP


13:00 - Surprising Targets of TFRP Liability


17:00 - Importance of Individual Tax Representation


21:00 - Defending Against TFRP Liability


25:00 - Consequences of Mishandling Trust Fund Taxes


29:00 - Proactive Measures to Avoid TFRP


33:00 - Importance of Tax Attorney Guidance


37:00 - Conclusion and Call to Action


About the Show

The Power of Tax Defense Attorneys: Tax Corner with Juda Gabaie is a podcast dedicated to empowering business owners and individuals in California with expert tax defense strategies. Featuring attorney Juda Gabaie, the show provides insights into navigating IRS penalties, payroll tax compliance, and tax dispute resolution. Through clear explanations and practical advice, the podcast helps listeners protect their finances and avoid costly tax issues.

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The Trust Fund Recovery Penalty: What Business Owners Must Know

The Trust Fund Recovery Penalty: What Business Owners Must Know

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