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Tax Research Problem-Chapter 14

Tax Research Problem-Chapter 14 - Tax Research Problem...

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Tax Research Problem I:14-75 Section 6672 states that "Those persons charged with the responsibility of collecting, accounting for, and paying over the tax to the government are subject to a penalty for willful failure to collect or account for the tax." "Responsible person" has been determined by the courts by considering such factors as: 1) Did the person have day to day management responsibilities? 2) Is he an officer, director, or major stockholder? 3) Was he involved and knowledgeable concerning the affairs of the corporation? 4) Did he sign checks, approve disbursements? 5) Was he or she a founder of the corporation? "Willful conduct" has been defined as the voluntary, conscious, or intentional act to prefer other creditors over the United States. The facts in this tax research problem are based on the cited case (Ernest W. Carlson v. U.S. ). In the tax research problem Carl Jones (1) was not the one who had final word on which
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