Many clients have tax problems resulting from the failure to pay payroll taxes.
The taxpayers in Evangelista were involved in a real estate corporation which collapsed in the late 1980's. They claimed that they were unable to pay the payroll withholding taxes and the social security contributions. The IRS determined that from 1989 through 1995 the taxpayers entered a series of schemes designed to defeat collection, by commingling personal and corporate funds and spent the monies on personal expenses and new businesses. The taxpayers did, however, file Forms 941 quarterly. After a jury trial the taxpayers were convicted of failure to pay withholding taxes.