Most of the time, the Trust Fund Recovery Penalty is associated with employers not making the payments of income taxes withheld from their employee’s paychecks over to the IRS. In this situations, the IRS holds the owner or responsible party of the business liable for these taxes, personally.
Recently, the 8th Circuit Court of Appeals affirmed an Iowa District Court opinion holding that a former president and CFO of an airline that is now defunct was a responsible person for excise taxes that were collected from the sale of airline tickets. If you are interested in reading the decision check out Ferguson v. U.S., 99 AFTR 2d 2007-897 (8th Cir.).