If an employer owes money to the IRS and can pay that liability back in full in short order, then the IRS will resolve the case that way. If, however, the employer will be unable to repay the liability back quickly then the IRS will begin trying to determine which owners and/or employees were responsible for the company’s failure to pay over the payroll taxes.
Once the IRS determines who it believes is responsible for the company’s failure to collect and remit the payroll taxes, it will begin the procedures to assess those individuals for the unpaid trust fund portion of the payroll taxes
Christopher G. Carmona CPA, APC