IRS Notice CP15: Trust Fund Recovery Penalty

What does an IRS CP15 notice mean?

A CP15 notifies you that the IRS has assessed a civil penalty against you personally. In the employment-tax context this is the Trust Fund Recovery Penalty (TFRP), which holds 'responsible persons' personally liable for the income and FICA taxes a business withheld from employees but failed to pay over to the IRS. The penalty equals 100% of the unpaid trust-fund taxes and can attach to your personal assets even though the underlying debt was the business's.

Why did you receive a CP15?

The IRS determined you were a responsible person who willfully failed to collect, account for, or pay the withheld payroll taxes — for example, an owner, officer, or bookkeeper with authority over the funds.

How to respond to a CP15 notice

You generally have 60 days to appeal the assessment, which is a critical deadline. If you disagree that you were a responsible or willful party, file a protest and provide evidence about your role and authority. If the penalty is valid, consider paying or negotiating an installment arrangement. Professional representation is strongly advisable given the stakes.

What happens if you ignore it?

The penalty becomes final and the IRS can pursue your personal wages, bank accounts, and property — separate from any action against the business. Liens and levies against you individually can follow.

Common resolutions

• Appeal within 60 days
• Pay the penalty
• Negotiate a payment plan

Related IRS notices

• CP161 — Balance Due — Penalty
• CP171 — Balance Due — Penalty Reminder
• CP259 — Return Not Filed — Business