The LTR 3027 confirms the Trust Fund Recovery Penalty has been assessed against you personally. Unlike the LTR 1153 (which proposes the assessment and gives you 60 days to appeal), the LTR 3027 means the assessment is final. The penalty amount is now posted to your individual tax account as a personal liability.
What This Means
You're personally liable for the trust fund portion of your business's unpaid employment taxes. This debt appears on your individual account, separate from the business's tax debt. It has its own 10-year collection statute starting from the assessment date. It cannot be discharged in bankruptcy. The IRS can collect it through liens, levies, and garnishments against your personal assets.
Options After Assessment
You can pay in full to stop interest and penalties. You can set up an installment agreement to pay over time. You can submit an Offer in Compromise if you can't pay the full amount within the collection period. You can request Currently Not Collectible status if paying would create a hardship.
You can also contest the assessment by paying the trust fund tax for one employee for one quarter and filing a refund claim. If the claim is denied or not acted on within 6 months, you can file a refund suit in federal district court. This is the "divisible tax" exception to the full-payment rule.
Multiple Responsible Persons
If the TFRP was assessed against multiple people, each is jointly and severally liable for the full amount. If one responsible person pays, the others' liability is reduced. Consider whether pursuing contribution from other responsible persons is worthwhile.
If the TFRP has been assessed against you, call us at (813) 229-7100. This is a serious personal liability that requires professional management.