IRM 5.17.7 (https://www.irs.gov/irm/part5/irm_05-017-007), is about corporate officers who have a duty "...to account for, collect, and pay over..." taxes and failed to perform that duty.
I don't think this is at all similar to jsrozner's solution, which is to assign liability to "...every person who has ever worked for IDScan at any level of management...".
The IRM is describing officers with culpability as individuals whereas jsrozner is really proposing to do without any individuate consideration of wrongdoing at all.
I don't think this is at all similar to jsrozner's solution, which is to assign liability to "...every person who has ever worked for IDScan at any level of management...".
The IRM is describing officers with culpability as individuals whereas jsrozner is really proposing to do without any individuate consideration of wrongdoing at all.