After a prolonged cash‑flow crunch, a car repair shop fell behind on payroll tax deposits. The owner was also personally assessed under the Trust Fund Recovery Penalty (IRC Section 6672), resulting in approximately $300,000 of federal payroll tax debt. After receiving Notices of Intent to Levy from the IRS, the Taxpayer contacted DeWitt Law.

We moved quickly to protect the client: we filed a timely Collection Due Process (CDP) request to stop enforcement and preserve appeal rights, brought filings current where needed, and performed a thorough financial analysis of the business and the owner. With a fully documented hardship package, we negotiated with the IRS.

The IRS placed both the business and the owner in Currently Not Collectible (CNC) status—halting levies and wage garnishments and effectively rendering the tax debt unenforceable while hardship continues. Our swift, professional advocacy gave the client breathing room to stabilize operations and stay compliant going forward. The business was saved.

Every case is different; CNC is subject to periodic IRS review and interest may continue to accrue. If payroll taxes or a TFRP are threatening your business, contact DeWitt Law to protect your assets and your livelihood.