What is the MAXIMUM penalty the IRS can assess for willful failure to deposit employment...

The IRS takes the collection of " trust fund taxes " —which include the federal income tax and the employee’s share of Social Security and Medicare taxes withheld by the employer—very seriously. Under Internal Revenue Code Section 6672, individuals responsible for the collection and payment of these taxes who willfully fail to do so can be held personally liable for a penalty equal to 100% of the unpaid trust fund tax. This is known as the Trust Fund Recovery Penalty (TFRP). " Willful " in this context means the responsible person was aware of the outstanding taxes and either intentionally disregarded the law or was plainly indifferent to its requirements. This penalty can be applied to corporate officers, employees, or even board members, and it cannot be discharged in personal bankruptcy, making it one of the most severe enforcement tools available to the IRS.