The Trust Fund Recovery Penalty is a penalty assessed against the owners, shareholders and/or officers of a corporation. Those individuals can be assessed the penalty when the corporation fails to pay payroll taxes to the U.S. Treasury. The "trust funds" comprise the Federal income taxes, Social Security and Medicare withholdings from employees paychecks.

The penalties assessed can range from minor liabilities to hundreds of thousands of dollars.

The first reason to hire an attorney is to have them investigate whether you should in fact be found responsible for the penalty. Generally, the penalty should only be assessed against people who have some control over the finances of the company, such that they could have made sure that the taxes were paid. Often, the Internal Revenue Service will target everyone on the bank account, even ministerial employees.

Additionally, if you ultimately do owe the penalties, then there is still the Internal Revenue Service Collection Division to negotiate with. Michael P. Tyson will work tirelessly to ensure that you obtain a reasonable agreement with the IRS and avoid tax liens and levies, if possible.