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Trust Fund Recovery Penalty (TFRP): Who Can Be Held Personally Liable for Unpaid Payroll Taxes
by: John B Love IIIPublished on: 02/01/2026A practical overview of the IRS Trust Fund Recovery Penalty (TFRP), including who may be deemed a “responsible person,” how the IRS defines willfulness, what Form 4180 interviews involve, and why responding to Letter 1153 within 60 days is critical.
Trust Fund Recovery PenaltyTFRPunpaid payroll taxesemployment taxeswithheld income taxFICA taxesresponsible person IRSwillfulness standardpayroll tax liabilityLetter 1153Form 4180 interviewIRS appeals requestForm 12203third-party payroll providerpayroll compliance
