Federal trust fund recovery penalty (1954)
The Internal Revenue Code let the IRS hold corporate officers personally liable, under the 'trust fund recovery penalty,' when a business withholds income and payroll taxes from employees but fails to send them to the government. The money is legally the government's from the moment it's withheld.
Officers of failing businesses faced personal liability and IRS levies on their own bank accounts and wages.
It hardened the principle that withheld taxes are never a business's money to spend, a rule states like Massachusetts mirror in their own law.
JP House of Pizza's biggest debt is withholding tax it took from employees' paychecks. The trust-fund rule is why governments pursue it so aggressively, and why Massachusetts can hold officers personally responsible.
