Case Study – A Coordinated PPIA & TFRP Resolution

Illustrative Case Study

How a two-phase process plays out when a family business, its owner, and a joint individual balance all face IRS collection at once: from investigation and strategy through a Partial Payment Installment Agreement (PPIA) and a Trust Fund Recovery Penalty (TFRP) investigation.

Fictional, composite scenario. This case study was created for illustrative purposes only. It does not describe an actual client, and no specific outcome is guaranteed for any taxpayer’s case. Every IRS matter depends on its own facts.

• SituationA family business, its owner, and a joint individual balance, all facing IRS collection activity.
• ApproachPhase 1 investigation and strategy, then a Phase 2 resolution scoped in writing.
• ResultAn accepted PPIA, a TFRP determination reflecting the owner’s actual role, and a completed payment plan.

Background

A small family-owned electrical contracting business had fallen behind on payroll tax deposits during a slow stretch. The IRS had opened a Trust Fund Recovery Penalty (TFRP) investigation against the owner personally, on top of the business’s own collection case. The owner and spouse also carried a joint individual balance from an earlier year.

Three interconnected liabilities, three points of IRS contact, and a family under real financial strain.

Enrolled Agent Alexander Garcia began by gathering the facts before recommending anything. He pulled IRS transcripts for the business and the individuals, reviewed every notice, and evaluated the household’s and the business’s finances side by side.

Looking at the three matters together, rather than as three separate engagements, showed how they overlapped. It also gave the family a realistic picture of what a Partial Payment Installment Agreement could look like given their means.

Phase 1 ended with a written recommendation. Nothing moved forward until the family reviewed it and signed off.

The Phase 2 engagement was scoped in writing before any work began. It covered three pieces of work, handled together:

• One consolidated financial package. The business’s cash flow, the household’s income and expenses, and the couple’s asset picture were assembled into a single collection information package. That gave the IRS one coherent, defensible financial narrative instead of three fragmented ones.
• A Partial Payment Installment Agreement. Alexander developed and pursued a PPIA based on the family’s documented circumstances and IRS requirements.
• Direct TFRP representation. He represented the owner through the responsible-party interview, working to make sure the facts of who controlled payroll decisions, and when, were presented accurately and in context rather than left to assumption.

How the Fee Worked

The same financial picture that supported a PPIA also meant a large up-front professional fee was not realistic. The Phase 2 fee was adjusted downward to reflect the family’s documented hardship, with credit applied for the Phase 1 work already completed.

The remaining balance was then spread across a flat monthly payment plan, with no interest, no financing charge, and no penalty for paying it off early. The total professional fee did not change based on how the payments were structured. The schedule was only a way to pay it, laid out in writing so there was no ambiguity about amounts, due dates, or what would happen if a payment were missed.

Had the case grown beyond the agreed scope, the family would have been told before any extra work was done, with a revised proposal in writing and no surprise invoices.

Outcome

The IRS accepted a Partial Payment Installment Agreement for the combined business and individual liabilities, based on the consolidated financial analysis. The TFRP investigation concluded with a determination that reflected the owner’s actual role rather than a default assumption. The family completed their payment plan on schedule, with a clear paper trail throughout.

What This Case Illustrates

Tax resolution work is often sold on the promise of a result. This composite case reflects a different emphasis: a federally licensed Enrolled Agent with more than 25 years of IRS experience building the financial case correctly the first time, a written recommendation and sign-off before each step, and fees that are scoped in writing and flexible about timing without changing what is owed or how the case is worked.

It also reflects what the process page promises: Alexander does not promise an outcome the IRS has not agreed to. Read the full Our Process page to see how each phase works.

Note – illustrative outcomes do not guarantee future results. Individual circumstances determine what resolution options are available.