All of the following regarding the Trust Fund Recovery Penalty under Section 6672 are true except: The Trust Fund Recovery Penalty is a penalty against any responsible person required to collect, account for, and pay over taxes held in trust who willfully fails to perform any of these activities. The Trust Fund Recovery Penalty can be discharged in bankruptcy if it was assessed more than 6 years before the bankruptcy is filed. A \"responsible person\" is one who has the duty to perform or the power to direct the act of collecting, accounting for, or paying over trust fund taxes. Pursuant to Roth v. United States, in some cases a person may be liable for failure to pay over withheld funds to the United States, even if ordered by the corporation's chief executive officer not to pay the taxes