Does a rule calling for the imposition of penalties by reason of misconduct intend to impose the penalties on the person who committed the misconduct?

A rule calling for the imposition of penalties by reason of misconduct would seem, giving words their most likely significance, to intend to impose the penalties on the person who committed the misconduct. To the extent that a statutory formulation visits penalties on a "taxpayer" by reason of misconduct, its reference to the misconduct justifying punishment seems most reasonably to refer to the misconduct of the taxpayer who will bear the punishment. For prudential reasons and in the application of conventional notions of derivative responsibility, the law extends a taxpayer's responsibility to include, under appropriate circumstances, the misconduct of persons chosen by the taxpayer to act on the taxpayer's behalf. See United States v. Boyle, 469 U.S. 241, 249-50, 105 S.Ct. 687, 691-92, 83 L.Ed.2d 622 (1985). I can see little reason, however, to construe this language as intending to impose penalties on the taxpayer by reason of the misconduct of persons who are neither the taxpayer, nor the taxpayer's chosen representatives.