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PLEASE go back to the original question thread.
You continue to ask these additional question as different questions
The answer to your question is, again, remember that the penalty itself is the amount that should have been withheld ... IF the withholding WAS done then there are funds there, in the trust, to pay WITH ... and the entity ITSELF always pays the other half.
The Sec. 6672(a) penalty amount IS the amount that was (or should have been) withheld ... this CONSTRUCTIVE trust is created when employee funds were withheld and then never paid in.
Remember the the TFRP equals the amount of money the employer withheld from employees’ wages (e.g., Social Security, Medicare, and income taxes) that was not remitted to the IRS.