Payroll tax penalty imposed. A person responsible for collecting and paying payroll tax can be held personally liable for willfully failing to do so. The penalty is 100% of the tax due. In one case, a doctor learned the employee he’d entrusted with these duties had instead embezzled $10 million. The doctor personally lent the medical practice $100,000 for payroll, but the IRS said those funds should’ve been encumbered to pay delinquent taxes. The doctor was charged a penalty of $4.3 million for willfully failing to pay the taxes. (DC TX, 118 AFTR 2d, 2016-5464)