Every payor required to deduct and withhold tax under section 316.2 is hereby made liable for such tax. For purposes of assessment and collection, any amount required to be withheld and paid over to the department and any additions to tax, penalties, and interest with respect thereto shall be considered the tax of the payor. All taxes deducted and withheld from payees pursuant to section 316.2 or under color of section 316.2 shall constitute a trust fund for the Commonwealth and shall be enforceable against such payor, his representative or any other person receiving any part of such fund.
72 P.S. § 7320.1