Denlea & Carton

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June 02, 2025

D&C Secures Jury Verdict for Client in Federal Payroll Tax Assessment Case

On May 9, 2025, Craig Cepler secured a verdict for our client in a case against the federal government, thus serving to vacate the IRS’s assessment of tax liabilities (exceeding $2 million, including fees and interest) against our client.

Our client’s husband owned an industrial cleaning company, and she provided minimal support to assist him. When the company failed to remit payroll taxes to the IRS in 2012 and 2013, the government assessed our client for the deficiencies. We brought suit in the Eastern District of New York on behalf of our client, seeking a declaratory judgment that she was not responsible for the company’s payroll tax obligations. After a one-week trial, the jury found in favor of our client on all counts, agreeing with our arguments that her minimal involvement was insufficient to deem her a responsible person under federal tax law and that she did not willfully fail to remit any withholdings to the IRS.

This verdict put an end to the 10+ year campaign by the IRS against our client. We are very proud to have reached this outcome for her and to give her repose from the IRS.

Jury Clears Biz Owner’s Wife Of $2M Payroll Tax Debt – Law360

MEET OUR ATTORNEYS

James R. Denlea

Jeffrey I. Carton

Catherine Friesen

Craig Cepler

Steven Schoenfeld

Amber Wallace

Christopher Dennis

Phil Smith

Martin McCann

Lindsey Leibowitz

Robert J. Berg

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