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What is IRC 6672?
PostedNovember 17, 2025
UpdatedNovember 17, 2025
ByKlemens Raab
Internal Revenue Code 6672 authorizes the IRS to impose a 100% penalty (equal to the unpaid trust fund amount) on individuals who are both:
– Responsible for ensuring payroll taxes are paid, and
– Willfully failed to do so.
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Resolving Payroll Tax Debts
- Why are payroll taxes a common issue for small businesses?
- Why are unpaid payroll taxes referred to as the "easiest loan to take and the hardest to pay back"?
- How do unpaid payroll taxes create personal liability for business owners?
- What portion of federal revenue is collected through payroll taxes?
- What are the primary payroll tax forms employers must file?
- What is FICA, and what are its components?
- What are "trust funds" in the payroll tax context?
- What is IRC 6672?
- What two conditions must be met for 6672 liability?
- How does the IRS define willfulness under 6672?
- What is the Trust Fund Recovery Penalty (TFRP)?
- What tool does the IRS use to investigate who is responsible for unpaid payroll taxes?
- Why should tax practitioners avoid letting clients attend Form 4180 interviews alone?
- What is IRS Letter 1153?
- How long does a taxpayer have to protest a Letter 1153 assessment?
- What is IRC 3505?
- What are the criminal statutes associated with payroll tax noncompliance?
- Has there been an increase in criminal payroll tax enforcement?
- What is the FTD Alert Program?
- What are the three FTD Alert categories?
- What is the IRS's goal with FTD Alerts?
- How quickly should a Revenue Officer respond to an FTD Alert?
- What is the IRS doing since 2022 to address payroll tax misuse?
- Can payroll tax misuse lead to income tax fraud charges?
- What should practitioners do if the IRS assesses a fraud penalty related to payroll tax use?
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