I.R.C. § 7501(a) General Rule —
Whenever any person is required to collect or withhold any internal revenue tax
from any other person and to pay over such tax to the United States, the amount of
tax so collected or withheld shall be held to be a special fund in trust for the
United States. The amount of such fund shall be assessed, collected, and paid in
the same manner and subject to the same provisions and limitations
(including penalties) as are applicable with respect to the taxes from which such
fund arose.
