One Hundred Percent Penalty

In cases where income and social security taxes that should be
withheld are not withheld or are not paid to the IRS, the 100
percent penalty may be applied. Under this penalty, certain officers
or employees of a corporation, certain members or employees of a
partnership, or other individuals who operate a business become
personally liable for the payment of the withheld taxes and can be
penalized an equal amount. Further explanation of this type of
assessment is in Publication 594, The Collection Process
(Employees Tax Acounts).

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