PENALTIES

 

Failure to Deposit - IRC section 6656: This is a 10 percent penalty applicable only to the employer paid portion of the tax. This means the employer's share of the FICA and all of the FUTA.

 

Delinquency - IRC section 6651: If the employment tax returns were filed late, delinquency penalties are applicable as with any other tax. A transcript should be consulted.

 

Negligence - IRC sections 6653(a) through 8909, IRC

section 6662 for 8912 and thereafter: Since the Tax

Reform Act of 1986, negligence has been applicable to

employment taxes. Prior to that Act there was no

provision for the application of the penalty.

 

Fraud - IRC section 6663 for returns due after December

31, 1989, IRC section 6653(b) for returns due prior to

that date: Though applicable to employment tax

returns, the same burden of proof as to intent exists

as with an income tax case.

 

BACKUP WITHHOLDING

 

Backup withholding should be considered where no

Forms 1099 are issued or identifying numbers supplied and the individual is not an employee. The issue is fully discussed in another section, but merits mention here because backup withholding is treated as an employment tax and reported on the Form 941. It is subject to the same statutes as the employment taxes even if no Forms 1099 were filed.

 

STATUTE AND CLOSING PROCEDURES

 

The normal statute date for timely filed Forms 941 for all quarters of a calendar year is April 15 of the fourth succeeding year, regardless of the due date of the quarterly return. For example: the normal statute date for all 1990 quarterly Forms 941 is April 15, 1994. If it is later, the statute expiration date of delinquent returns is 3 years from the filing date.

 

The statute date for Form 940, FUTA, is 3 years from the due date or filing date, whichever is later. Since the due date for filing the Form 940 is January 31 of the year following the calendar year, the expiration date for a timely filed 1990 return is January 1, 1994.

 

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