A computer consulting business had expanded over the years requiring the addition of several employees to provide necessary service to meet customer demands. The firm had undertaken a significant reduction of staff, on their own, attempting to regain profitability. However, the consequences of several months of unprofitable operations resulted in unpaid payroll taxes due to the IRS in the amount of $500,000. The company had entered into a monthly installment agreement with the IRS, but their payments were insufficient to pay even the accrued interest. Further, the firm’s officers had been personally assessed the trust fund portion of these unpaid payroll taxes by the IRS. Federal tax liens had been filed against the company and its officers.