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["Title","First Name","Last Name","Gender"]
["President","John","Doe","Male",{"$f":"IF(D2=\"Male\",\"Mr. \",IF(D2=\"Female\",\"Ms. \",\"\"))","v":"Mr. "}]
[]
[{"$f":"$E$2&$C$2&E4\n\n&$E$2&$C$2&E5&$E$2&$C$2&E6\n\n&$E$2&$C$2&E7","v":"Mr. Doe is fully responsible and willful for the trust fund tax.  Mr. Doe signed payroll checks, 941 returns and utilized full discretion in redirection of funds to pay obligations other than trust fund taxes on behalf of the business.  Mr. Doe had full hiring/firing authority, held a position of authority and was fully aware of the non payment of the 941 payroll taxes in lieu of other corporate obligations. Mr. Does assets indicate collectability."},null,null,null," is fully responsible and willful for the trust fund tax.  "]
[null,null,null,null," signed payroll checks, 941 returns and utilized full discretion in redirection of funds to pay obligations other than trust fund taxes on behalf of the business.  "]
[null,null,null,null," had full hiring/firing authority, held a position of authority and was fully aware of the non payment of the 941 payroll taxes in lieu of other corporate obligations. "]
[null,null,null,null,"s assets indicate collectability."]
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[{"$f":"$E$2&$C$2&E12&\"  \"\n\n&$E$2&$C$2&E13&$E$2&$C$2&E14&\"  \"","v":"Mr. Doe is responsible, willful & collectible.  Mr. Doe has signature authority on the company's bank account and uses that authority to sign payroll and operations checks.  Mr. Doe has continued to pay other obligations of the company after knowledge of the delinquent taxes, indicating willfulness.    "},null,null,null," is responsible, willful & collectible."]
[null,null,null,null," has signature authority on the company's bank account and uses that authority to sign payroll and operations checks.  "]
[null,null,null,null," has continued to pay other obligations of the company after knowledge of the delinquent taxes, indicating willfulness.  "]
[null,null,null,null," has continued to pay other obligations of the company after knowledge of the delingquent taxes, indicating willfulness.  "]
[]
[]
[]
[{"$f":"$E$2&$C$2&\", is the \"&$A$2&E19&\"  \"\n\n&$E$2&$C$2&E20&$E$2&$C$2&E21&$E$2&$C$2&E22&\"  \"\n\n&$E$2&$C$2&\"'\"&E23&\"  \"","v":"Mr. Doe, is the President of the company.  Mr. Doe is fully responsible, willful and collectible for the trust fund tax.   Mr. Doe prepared 941 returns and determined which checks will be paid.  Mr. Doe was fully aware of the non-payment of the 941 payroll taxes in lieu of other corporate obligations.  Mr. Doe's age, health and future earnings potential indicate collectability.  "},null,null,null," of the company."]
[null,null,null,null," is fully responsible, willful and collectible for the trust fund tax.   "]
[null,null,null,null," prepared 941 returns and determined which checks will be paid.  "]
[null,null,null,null," was fully aware of the non-payment of the 941 payroll taxes in lieu of other corporate obligations."]
[null,null,null,null,"s age, health and future earnings potential indicate collectability."]
[]
[{"$f":"$E$2&$C$2&\", as \"&$A$2&E25&\"  \"\n\n&$E$2&$C$2&\"'\"&E26&\"  \"&$E$2&$C$2&\" \"&E27&\"  \"&$E$2&$C$2&E28&\"  \"\n\n&$E$2&$C$2&E29&\"  \"","v":"Mr. Doe, as President of the business, having authority and responsibility for the payment of said trust fund taxes for these periods, willfully failed to pay them.  Mr. Doe's authority and responsibility extended to; the signing of checks, making federal tax deposits, signing of tax returns, hiring and firing of employees, and making the day to day determinations of which creditors to pay.  Mr. Doe willfully failed to pay trust fund taxes, which is evident by a determination to pay other creditors such as utilities, wages, suppliers, and vendors in favor of these trust fund taxes.   Mr. Doe signed the Form 941s and was aware they were not paid.  Therefore,   Mr. Doe is both responsible and willful for these periods and should be assessed the TFRP. A review of personal financial conditions indicate this assessment should be collectible from assets, income and future earning potential.  "},null,null,null," of the business, having authority and responsibility for the payment of said trust fund taxes for these periods, willfully failed to pay them."]
[null,null,null,null,"s authority and responsibility extended to; the signing of checks, making federal tax deposits, signing of tax returns, hiring and firing of employees, and making the day to day determinations of which creditors to pay."]
[null,null,null,null,"willfully failed to pay trust fund taxes, which is evident by a determination to pay other creditors such as utilities, wages, suppliers, and vendors in favor of these trust fund taxes. "]
[null,null,null,null," signed the Form 941s and was aware they were not paid.  Therefore, "]
[null,null,null,null," is both responsible and willful for these periods and should be assessed the TFRP. A review of personal financial conditions indicate this assessment should be collectible from assets, income and future earning potential."]
[]
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[{"$f":"E33&E2&C2&E34&\" \"&A2&E35&CHAR(10)&\"As the \"&A2&E36&E2&C2&E37&\"  \"&E2&C2&E38&E39&E2&C2&E40&A2&E41&E42&E2&C2&E43","v":"In Farris v. United States, the court stated that absent evidence to the contrary any high-ranking corporate official, such as a vice-president, is considered to be a responsible person.  Mr. Doe as  President of the company, was a high ranking official.\nAs the President there is an expectation of authority in the company's financial policy decisions.  Therefore it is reasonably inferred that Mr. Doewould have knowledge of the company's liabilities, including taxes and had authority and input into the the authorization of payment to bills and creditors.    Mr. Doe is therefore willful.\n\nFurther, responsibility is tested by whether the person has \u0080\u009ceffective power to pay the taxes owed\u0080\u009d, Purcell v. United States, 1F.3d 932, 937 (9th Cir. 1993).  A person is deemed to have such power if he/she possesses the authority to exercise significant control over the company\u0080\u0099s financial affairs, whether or not such control is in fact exercised.Mr. Doe, as the President and further evidenced by his signature authority on the company bank account, had that power and is therefore responsible.\n\nLastly, a financial review of available information on IDRS indicate that Mr. Doe is collectable."},null,null,null,"In Farris v. United States, the court stated that absent evidence to the contrary any high-ranking corporate official, such as a vice-president, is considered to be a responsible person.  "]
[null,null,null,null," as "]
[null,null,null,null," of the company, was a high ranking official."]
[null,null,null,null," there is an expectation of authority in the company's financial policy decisions.  Therefore it is reasonably inferred that "]
[null,null,null,null,"would have knowledge of the company's liabilities, including taxes and had authority and input into the the authorization of payment to bills and creditors.  "]
[null,null,null,null," is therefore willful.\n\n"]
[null,null,null,null,"Further, responsibility is tested by whether the person has \u0080\u009ceffective power to pay the taxes owed\u0080\u009d, Purcell v. United States, 1F.3d 932, 937 (9th Cir. 1993).  A person is deemed to have such power if he/she possesses the authority to exercise significant control over the company\u0080\u0099s financial affairs, whether or not such control is in fact exercised."]
[null,null,null,null,", as the "]
[null,null,null,null," and further evidenced by his signature authority on the company bank account, had that power and is therefore responsible.\n\n"]
[null,null,null,null,"Lastly, a financial review of available information on IDRS indicate that "]
[null,null,null,null," is collectable."]
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[null,null,null,null,"\nAs the CEO, there is an expectation of authority in the company's financial policy decisions.  Therefore it is reasonably inferred that he would have knowledge of the company's liabilities, including taxes and that he had authority and input into the the authorization of payment to bills and creditors.  Mr. McKinley is therefore willful.\nFurther, responsibility is tested by whether the person has â\u0080\u009ceffective power to pay the taxes owedâ\u0080\u009d, Purcell v. United States, 1F.3d 932, 937 (9th Cir. 1993).  A person is deemed to have such power if he/she possesses the authority to exercise significant control over the companyâ\u0080\u0099s financial affairs, whether or not such control is in fact exercised. Mr. McKinley , as the CEO and further evidenced by his signature authority on the company bank account had that power and is therefore responsible.\nLastly, a financial review of available information on IDRS indicate that he is collectable."]

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