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Trust Fund Recovery Penalties: Civil & Criminal Concerns


Cost Free
Presentation Length 1.0 hour

Recorded DateOctober 22, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Join this session to examine trust fund recovery penalties and how taxpayers may be potentially affected. We will cover the Internal Revenue Service’s process for civil assessments of trust fund recovery penalties, pursuant to Section 6672 of the Internal Revenue Code. Additionally, we will examine taxpayers’ potential criminal exposure under Section 7202 of the Internal Revenue Code. Finally, we will examine relevant and recent federal and Tax Court cases related to trust fund recovery penalties.
Learning Objectives:

  • Identify the scope of trust fund recovery penalties

  • Recognize the significance of “responsible person” and “willfulness”

  • Determine the Internal Revenue Service’s process for civil assessments of trust fund recovery penalties

  • Evaluate a taxpayer’s criminal exposure under Section 7202 of the Internal Revenue Code

  • Recall examples of relevant cases involving trust fund recovery penalties

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Zachary Montgomery is a dual-credentialed attorney and CPA. He practices federal and state tax litigation, white-collar defense, business and tax planning, and litigation. Montgomery has experience representing both businesses and individuals in federal tax controversies, including appeals, examinations, penalty abatement, and collection matters. He has also represented taxpayers—from small organizations to Fortune 500 companies—with Texas franchise tax refund claims, audits, penalty abatement, and corporate structuring.

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Mr. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. Mr. Freeman has been recognized multiple times by D Magazine as one of the Best Lawyers in Dallas and by Super Lawyers and Texas Monthly magazine. He was recently honored by the American Bar Association, receiving its “On the Rise – Top 40 Young Lawyers” in America award, and recognized as a Top 100 Up-And-Coming Attorney in Texas. He was also named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas by AI.

He serves on the law school faculty at SMU’s Dedman School of Law, where he teaches a federal income tax law course. He is a frequent public speaker across the country, presenting and educating on various legal topics. He is the President of the North Texas chapter of the American Academy of Attorney-CPAs, a former executive board member of the Texas Society of CPAs, and the Texas Society of CPAs chairman-elect. He is also a council member for the Tax Section of the Texas State Bar.

Mr. Freeman represents clients in litigation and disputes, with a particular focus on federal and state tax controversies, as well as white-collar and financial disputes, both civil and criminal. He handles IRS audits and other investigations and represents clients facing tax and white-collar or financial-related charges. He also advises and assists clients with tax and regulatory compliance, including domestic and international tax planning and regulatory reporting requirements, as well as cryptocurrency and Blockchain implementations.

About Our Presenter

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Freeman Law is a tax, white-collar, and litigation boutique law firm based in the Dallas-Fort Worth Metroplex with clients throughout the world. Founded by a dual-credentialed attorney-CPA and law professor, Freeman Law offers unique and valued counsel, insight, knowledge, and experience. We represent individuals and businesses of all sizes, from companies on the Fortune 100 fastest-growing companies list to family-owned businesses. With a background in complex tax planning and litigation, white-collar criminal and civil disputes, and sophisticated civil litigation, Freeman Law is where clients turn when the stakes are high and the issues are complex.