Would a signor on a company’s bank signature card that became a signor after the tax was owed be liable for previously accrued payroll tax (assume payroll taxes were paid current for new payroll starting from the date the signor signed the card to present)?

The new signor would not be responsible in theory; however, in practice if the IRS summons the bank signature card and the new signor’s name exists, he or she may have to show via a 4180 interview that they were not a responsible person. This should be easy to prove but lack of defending oneself could lead to a Civil Penalty assessment.

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