Trust Fund Recovery Penalty: SCOTUS Asked Whether Reasonable Cause is a Defense

As I've mentioned previously, under IRC § 6672, the IRS may assess the Trust Fund Recovery Penalty only if the person responsible for collecting or paying trust fund taxes willfully failed to pay them.  A split exists among the federal appeals courts as to whether reasonable cause constitutes a defense to willfulness under IRC § 6672, and the petition asks this question to the Supreme Court of the United States. See also Business Owner Seeks Supreme Court Review of Decision Holding Her Liable for Trust Fund Taxes, 2011 TNT 207-24, October 26, 2011.