Represented former officers of a company that had filed for bankruptcy protection during the early stages of the COVID-19 pandemic. The IRS asserted Trust Fund Recover Penalties exceeding $900,000 for each former officer. Remarkably, the underlying payroll debt stemmed from activities during the bankruptcy proceedings and was overseen by the district court. ATL was engaged, protested the proposed assessment and without the necessity of slogging through the administrative appeals process, efficiently obtained a full concession from the IRS.
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