David J. Chadwick v. Commissioner

154 T.C. No. 5

UNITED STATES TAX COURT DAVID J. CHADWICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17049-18L. Filed January 21, 2020. P was the sole member of LLC1 and LLC2, each of which failed to pay employment taxes with respect to its employees’ wages. Different revenue officers (ROs) were assigned to investigate these matters. The ROs concluded that P was a “responsible person” of each LLC and was thus required to collect and pay over its employ- ment taxes. See I.R.C. sec. 6672(a). Each RO completed a Form 4183, Recommendation re: Trust Fund Recovery Penalty…