Statute of Limitations - Trust Fund Recovery Penalties

One of the most common mistakes that I see practitioners and the IRS make is incorrect assessments of Trust Fund Recovery Penalties (TFRP). This is partially due to an old IRS idea that TFRP did not have a statute of limitations. However, that idea was quickly shot down when it was taken to court. IRM Section 5.19.14.1.5 is a great place to look when you have TFRP issues.
As practitioners, one of the first steps in exercising due diligence for our clients is to check all applicable statutes of limitations to see if any apply to your client.
This chart is a great breakdown of when a TFRP must be assessed. Any assessment outside of this range would be an incorrect assessment:

Withholding or Federal Insurance Contribution Act (FICA),	Three years from the succeeding April 15th or three years from the date return was filed; whichever is later.
Excise or Railroad Retirement Tax Act (RRTA),	Three years from the due date of return, without regard to any extension; or three years from the date return was filed; whichever is later.
Withholding, FICA, Excise or RRTA returns that are: filed under IRC 6020(b)(1), Returns Executed by Secretary false or fraudulent willful attempt to evade tax; or not filed	No limitation period.