Rickey B. Barnhill v. Commissioner

155 T.C. No. 1

UNITED STATES TAX COURT RICKEY B. BARNHILL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10374-18L. Filed July 21, 2020. P was a director of Company (“C”). C failed to pay over to R employment withholding taxes for its employees for 10 quarters in 2010-12. R sent and P received a Letter 1153, “Trust Fund Recovery Penalty [“TFRP”] Letter”, proposing to assess TFRPs under I.R.C. sec. 6672 against P as a responsible person for C. P filed an appeal disputing the TFRP liability before R’s Office of Appeals (“Appeals”). Appeals sent P a Letter 5157 scheduling…