The IRS has announced a new option for certain taxpayers to request more time after an Employee Retention Credit (ERC) claim is disallowed. Taxpayers generally have two years from the date of Letter 105-C or 106-C to resolve the claim administratively or file a refund suit in federal court, and filing an appeal does not extend that deadline. Eligible taxpayers with six months or less remaining may use Form 907 through the IRS Document Upload Tool while awaiting IRS review. Manufacturers with unresolved ERC claims should not assume the process is protecting their rights. Consult a tax adviser now. 4/29/2026
ERC Disallowance? Watch the Clock
05/01/2026