List out reasons that could provide a basis for an appeal to the IRS, given the following information:

A new client, Rachel Green, has come to your office (the Orange & Blue CPA firm), with an IRS notice. The notice indicates that the IRS is proposing to assess the Trust Fund Recovery Penalty under IRC Section 6672 against her. The penalty is related to unpaid employment taxes from a failed business that Rachel participated in with her now deceased husband. However, Rachel is adamant that she had no idea the business was not paying its employment taxes and does not understand how she can be personally liable for so much in taxes from a failed business that was (mostly) owned and operated by her late husband.

Facts:

1. Rachel and her husband started a business venture in 2015. The model was an online direct-to-consumer business delivering monthly boxes of hand-crafted artisinal toothpastes to customers. The company had 100 shares of stock outstanding - split evenly between her and her husband.

2. By the end of 2017, the company had 12 full-time employees who worked in various roles.

3. The company started to decay in early 2018 when the FDA sent a letter that lead to the inspection of their product - resulting in significant legal fees and other expenses.

4. By the end of 2018, the FDA issued a cease and desist letter prohibiting their sale of toothpaste.

5. Rachel's husband became ill in 2019 and passed away from the use of the unsafe toothpaste. He passed in 2020.

6. IRS agent contacted Rachel this past summer and advised that that she was being held liable for payroll taxes that were withheld but not remitted to the IRS by the company. She owed nearly $20,000

7. Rachel was named president of the company and had general supervision, direction, and control of the business and affairs of the corporation. She received a salary of $75,000 annually.

8. Rachel's husband handled all the money issues and never inquired about the employee's checks because she assumed that her husband had a good grasp of the company's financial situation.