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The Employee Retention Credit: How to Litigate and Resolve Claims

by Shawn O’Brien, Michael J. Scarduzio and Samuel F. Hamer | Apr 10, 2025 | IRS Appeals

The Employee Retention Credit (ERC) was designed to help employers keep their employees on payroll during the COVID-19 pandemic by offering a refundable tax credit against certain employment taxes. Despite the Internal Revenue Service (IRS) issuing more than $242 billion in ERC as of early 2025, the processing and payment of these claims have faced significant delays and scrutiny.

In a recent Bloomberg Tax article, McDermott’s tax controversy and litigation team shared a broad overview of the stages of ERC claims and potential ways in which taxpayers can resolve them. Key takeaways include:

ERC claims can be in one of four stages: no IRS action, IRS examination, formal disallowance, or IRS recapture. Understanding the implications of each stage can be crucial for maximizing taxpayers’ chances of receiving and keeping ERC.
Thousands of ERC claims remain stagnated in the IRS’s administrative review process. Litigation can be a powerful tool to expedite the payment of ERC claims.
Taxpayers must be highly vigilant about the applicable statutes of limitations concerning ERC refund claims. Not understanding these deadlines can undermine the potential for a successful ERC claim.
The IRS is capable of recapturing ERC that it believes was erroneously allowed. However, the mechanisms for recapture may be susceptible to legal challenge, and taxpayers should be aware of their litigation options.

Read the full article.

IRS Roundup January 20 – 31, 2025

by Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio | Feb 13, 2025 | Court Procedure Matters, IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025.

TAX-CONTROVERSY-RELATED DEVELOPMENTS

January 22, 2025: The IRS reminded taxpayers that they have rights – outlined in the Taxpayer Bill of Rights – any time they interact with the IRS. These rights cover a wide range of topics and issues and lay out what taxpayers can expect when interacting with the IRS. Taxpayers should also know that the Taxpayer Advocate Service (TAS) is an independent organization within the IRS that helps taxpayers and protects their rights for free. TAS can help if assistance is needed to resolve an IRS problem, if a problem is causing financial difficulty, or if an IRS system or procedure isn’t working as it should.

January 24, 2025: Alarm Concepts Inc. filed a class action lawsuit against the IRS and Booz Allen Hamilton Inc. after being notified that its tax data was stolen and leaked by Charles Littlejohn, a Booz Allen employee contracted to work at the IRS. Littlejohn pled guilty in October 2023 to unlawfully disclosing confidential tax returns and return information between 2018 and 2020. The breach appears to have affected tens of thousands of taxpayers.

The lawsuit alleges that the IRS failed to implement adequate cybersecurity measures despite repeated warnings, and that Booz Allen neglected to protect the data. The stolen information includes sensitive details from Forms 1099 and Schedule K-1. The lawsuit highlights ongoing risks of identity theft and fraud for the affected taxpayers.

The lawsuit asserts that Alarm Concepts and class members are entitled to statutory damages of $1,000 for each unauthorized inspection or disclosure, as well as punitive damages because the disclosures were willful or the result of gross negligence.

January 30, 2025: The US Senate Committee on Finance released a bipartisan discussion draft of legislation aimed at improving IRS procedures and administration. The proposed bill, named the Taxpayer Assistance Service Act (TAS Act), seeks to enhance the taxpayer experience by facilitating better communication with the IRS, streamlining tax compliance and dispute processes, and ensuring timely expert assistance. Key provisions include improving “math error” notices, expanding US Tax Court jurisdiction, simplifying foreign bank account report compliance, and expanding access to the IRS Independent Office of Appeals. The draft also aims to expand the independence of the National Taxpayer Advocate (NTA) from the IRS and strengthen the IRS whistleblower program while protecting the confidentiality of taxpayer information.

The proposed bill reflects nonpartisan recommendations and seeks to address challenges faced by taxpayers within the current tax system. Proponents of the proposed bill include the current NTA Erin Collins and the long-serving former NTA Nina Olson. Olson described the TAS Act as a “sweeping piece of legislation that promises to improve federal tax administration and increase taxpayer protections.”

TAX RETURN FILING SEASON DEVELOPMENTS

January [...]

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IRS Roundup January 13 – 17, 2025

by Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio | Feb 4, 2025 | Alternative Dispute Resolution, IRS Appeals, IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025.

TAX CONTROVERSY-RELATED DEVELOPMENTS

January 15, 2025: The US Department of the Treasury (Treasury) and the IRS published final regulations, providing guidance on the resolution of federal tax controversies by the IRS Independent Office of Appeals (IRS Appeals). These final regulations are applicable to requests for IRS Appeals consideration made on or after February 14, 2025.

The Taxpayer First Act of 2019 (TFA) codified IRS Appeals and prescribed that its consideration should be “generally available to all taxpayers” who wished to resolve their federal tax controversies. Proposed regulations published on September 13, 2022, identified 24 exceptions to the term “federal tax controversy.” These exceptions preclude IRS Appeals from considering taxpayer challenges to the constitutionality of statutes and the validity of regulations, as well as the procedural validity of notices and revenue procedures. During the comment period for the proposed regulations, the exceptions regarding statutory/regulatory challenges were the focus of most public comments by far. However, the exceptions were left almost entirely unchanged in the final version of the regulations.

Practice Point: Because the TFA prescribes that IRS Appeals consideration should be “generally available to all taxpayers,” we expect judicial challenges to the validity of the final regulations on Administrative Procedure Act and substantive grounds. In the interim taxpayers should continue asserting their arguments challenging the validity of deficient guidance on constitutional or other grounds.

Relatedly, the IRS issued Announcement 2025-6, which describes three pilot initiatives that will test changes to existing Alternative Dispute Resolution programs. These programs are designed to help taxpayers resolve tax disputes earlier and more efficiently. The pilots focus on Fast Track Settlement, a program that allows IRS Appeals to mediate disputes between a taxpayer and the IRS while the case is still within the jurisdiction of the examination function, and Post-Appeals Mediation, a program in which a mediator helps foster a settlement between IRS Appeals and the taxpayer.

CLEAN ENERGY-RELATED DEVELOPMENTS

January 14, 2025: The Treasury and the IRS published final regulations regarding the clean electricity production credit under Internal Revenue Code (Code) Section 45Y and the clean electricity investment credit under Code Section 48E, established by the Inflation Reduction Act of 2022 (IRA). These final regulations provide rules for determining greenhouse gas emissions rates resulting from the production of electricity, petitioning for provisional emissions rates, and determining eligibility for these credits in various circumstances. The final regulations affect all taxpayers who claim the clean electricity production credit with respect to a qualified facility or the clean electricity investment credit with respect to a qualified facility or energy storage technology, as applicable, that is placed in service after 2024.

January 15, 2025: The IRS issued Notice 2025-9, which provides a safe harbor for the incremental cost of certain qualified commercial clean vehicles placed in service in calendar year [...]

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Weekly IRS Roundup July 24 – July 28, 2023

by Evan Walters | Aug 1, 2023 | IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 24, 2023 – July 28, 2023.

July 24, 2023: The IRS released Internal Revenue Bulletin 2023-30, which includes proposed regulations that specify the methodology for constructing the corporate bond yield curve used to calculate present value under a defined benefit plan. The Internal Revenue Bulletin also highlights the following:

Announcement 2023-18 relieves taxpayers from reporting the new stock repurchase excise tax under § 4501.

Announcements 2023-19 and 2023-20 revoke the tax-exempt status of certain organizations.

Notice 2023-37 modifies prior guidance regarding benefits related to testing and treating COVID-19.

Notice 2023-50 announces that the applicable percentage for purposes of determining percentage depletion on marginal properties for 2023 is 15%.

Notice 2023-51 publishes the inflation adjustment factor and the reference price for 2023 for the renewable electricity production credit under § 45.

T.D. 9976 provides final regulations that facilitate the transition from the London Interbank Offered Rate (LIBOR) to other interbank offered rates (IBORs).

July 24, 2023: The IRS released Tax Tip 2023-93, warning businesses and tax-exempt organizations about misleading employee retention credit claims. Scammers and unscrupulous promoters have been running aggressive broadcast advertising, direct mail solicitations and online promotions for the credit, many of which misrepresent and exaggerate who can qualify for the credit.

July 24, 2023: The IRS announced that revenue officers will no longer make unannounced visits to taxpayers’ residences in all but a few narrow circumstances. Instead, they will schedule visits via mailed letters.

July 25, 2023: The IRS released Tax Tip 2023-94, advising that applicable entities, including tax-exempt and governmental entities that would otherwise be unable to claim certain credits because they do not owe federal income tax, can benefit from some clean energy tax credits. If an entity opts to receive an elective payment, the amount of such credits is treated as a payment of tax, and overpayments will result in a refund.

July 25, 2023: The IRS released Notice 2023-53, which provides guidance on the corporate bond monthly yield curve, spot segment rates used under § 417(e)(3) and the 12-month average segment rates under § 430(h)(2).

July 25, 2023: The IRS published a special summer series discussing the Identity Protection PIN Opt-In Program, which can provide an extra layer of security for taxpayers filing their tax returns.

July 26, 2023: The IRS released Tax Tip 2023-95, reminding taxpayers that IRS Free File remains available until October 16 for those who still need to file a 2022 tax return.

July 26, 2023: The IRS released Revenue Procedure 2023-26, which provides a program for the fast-track processing of private letter ruling requests, replacing the pilot program described in
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Weekly IRS Roundup June 12 – June 16, 2023

by Sarah M. Raben | Jun 20, 2023 | IRS Appeals, IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 12, 2023 – June 16, 2023.

June 12, 2023: The IRS released Internal Revenue Bulletin 2023-24, which highlights the following:

Notice 2023-43: This notice provides guidance with respect to Section 305 of the SECURE 2.0 Act of 2022. Section 305 provides for the expansion of the Employee Plans Compliance Resolution System currently set forth in Revenue Procedure 2021-30. This notice provides interim guidance in advance of any updates to Revenue Procedure 2021-31 and is not intended to be comprehensive.

June 12, 2023: The IRS announced a new series of special events at this year’s IRS Nationwide Tax Forums, including sessions focused on practice management, the taxpayer experience, cybersecurity and a town hall meeting with the National Taxpayer Advocate.

June 12, 2023: The IRS released Tax Tip 2023-79, reminding taxpayers that when they disagree with an IRS decision, they can submit a written request to have the IRS Independent Office of Appeals (IRS Appeals) review the decision.

June 13, 2023: The IRS announced that IRS Commissioner Danny Werfel will deliver the keynote speech at the Nationwide Tax Forum in Atlanta on July 25 to July 27. The three-day session will provide tax professionals with multiple opportunities to learn more about tax law changes and IRS transformation efforts.

June 13, 2023: The IRS released Tax Tip 2023-80, reminding taxpayers that they may be able to avoid the time and expense of a court trial by asking IRS Appeals to review their case if they disagree with an IRS decision. When IRS Appeals officers review cases submitted by taxpayers, they meet informally and consider both the taxpayers’ and the IRS’s position.

June 14, 2023: The IRS announced proposed regulations and frequently asked questions that describe rules for entities that earn certain clean energy credits and choose to make an elective payment election and rules for eligible taxpayers who elect to transfer certain credits to unrelated parties. For tax years beginning after December 31, 2022, certain eligible taxpayers can elect to transfer all or a portion of eligible tax credits to unrelated taxpayers in exchange for cash payments.

June 14, 2023: The IRS issued proposed regulations that provide guidance on the implementation of the elective payment provisions of the Advanced Manufacturing Investment Credit, which was established by the Creating Helpful Incentives to Produce Semiconductors Act of 2022. This credit incentivizes the manufacture of semiconductors and semiconductor manufacturing equipment within the United States.

June 14, 2023: The IRS released Tax Tip 2023-81, reminding taxpayers to think about various tax considerations when selling their home. For example, they may qualify to exclude all or part of any capital gain from the sale of their home, [...]

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Weekly IRS Roundup May 8 – May 12, 2023

by Sarah M. Raben | May 15, 2023 | IRS Appeals, IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 8, 2023 – May 12, 2023.

May 8, 2023: The IRS released Internal Revenue Bulletin 2023-19, which highlights the following:

Revenue Procedure 2023-22: This revenue procedure provides qualified mortgage bond issuers and mortgage credit certificate issuers with (1) the nationwide average purchase price for residences located in the United States, and (2) the average area purchase price safe harbors for residences located in statistical areas in each state, the District of Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands and Guam.

Announcement 2023-14: This announcement provides the revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).

Notice 2023-34: This notice provides that convertible virtual currency should be treated as property for federal tax purposes and general tax principles applicable to property transactions apply to transactions using convertible virtual currency. This notice modifies Notice 2014-21 by revising a sentence in the background section to remove the statement that virtual currency does not have legal tender status in any jurisdiction, among other changes.

Revenue Procedure 2023-21: This revenue procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under Section 842(b) for taxable years beginning after December 31, 2021.

Revenue Ruling 2023-9: This revenue ruling provides the applicable federal rates for federal income tax purposes for May 2023. The short-term federal interest rate is 4.30%, the mid-term rate will drop to 3.57% and the long-term rate will fall to 3.72%

May 8, 2023: The IRS announced Saturday hours for May 13 in more than 40 locations across 25 states. The Saturday hours were to help taxpayers who may have a tax concern or questions about an IRS notice.

May 8, 2023: The IRS released Tax Tip 2023-63, providing IRS websites and other publications with tax-related disaster relief information that can help taxpayers.

May 9, 2023: The IRS announced that it will accept applications for Low Income Taxpayer Clinic (LITC) matching grants from May 8, 2023, to June 26, 2023. The funding will be for the 2023 calendar year. The IRS awards matching grants to qualifying organizations to develop, expand or maintain an LITC. An LITC must match every dollar of funding awarded by the IRS.

May 9, 2023: The IRS released Tax Tip 2023-64, highlighting the Taxpayer Bill of Rights and the right to challenge the IRS’s position.

May 10, 2023: The IRS released Notice 2023-39, which describes proposed amendments to [...]

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IRS Appeals Is Looking for Suggestions on Improving Conference Access

by Kevin Spencer and Sarah M. Raben | May 12, 2023 | IRS Appeals, IRS Guidance
The Internal Revenue Service (IRS) has invited suggestions on improving conference options at the Independent Office of Appeals (IRS Appeals) for taxpayers and representatives who are not located near an IRS Appeals office. Specifically, IRS Appeals is inviting comments on:

Revising or replacing the “circuit riding” policy in IRM 8.6.1.5.1.1 to expand opportunities for timely in-person conferences for taxpayers living in certain states

Facilitating participation at in-person conferences when taxpayers and their representatives are not co-located

Best practices for conducting hybrid conferences, where some participants meet in person and others join by video or telephone

If a case must be transferred within IRS Appeals to facilitate an in-person conference, how best to avoid substantial delay in resolving the underlying tax dispute and

Encouraging participation in in-person and video conferences by taxpayers in historically marginalized communities or with limited English proficiency and ensuring accessibility by persons with disabilities.

Comments should be sent to ap.taxpayer.experience@irs.gov by July 10 for consideration.

Practice Point: COVID-19 prompted many modernizations at the IRS, including the expansion of remote technology resources. Taxpayers get to choose how to interact with IRS Appeals, but that choice, whether via telephone, video conference or in person, could impact their experience. Requests like these by the IRS are valuable opportunities that can affect how IRS Appeals operates in the future.

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Weekly IRS Roundup December 12 – December 16, 2022

by McDermott Will & Emery | Dec 19, 2022 | IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 12, 2022 – December 16, 2022.

December 12, 2022: The IRS released Internal Revenue Bulletin 2022-50, which highlights the following:

Revenue Procedure 2022-41: This guidance specifies when information shown on an income tax return will be an adequate disclosure for purposes of reducing an understatement of income tax under Section 6662(d) and for purposes of avoiding the Section 6694(a) preparer penalty. This revenue procedure updates Revenue Procedure 2021-52 and applies to any income tax return filed on 2022 tax forms for a taxable year beginning in 2022 and any income tax return filed in 2023 on 2022 tax forms for short taxable years beginning in 2023.

December 12, 2022: The IRS reminded people over the age of 72 to start withdrawals from individual retirement arrangements (IRAs) and retirement plans in order to avoid penalties. Required minimum distributions (RMDs) are the minimum amounts that many retirement plan and IRA account owners must withdraw annually after they reach age 72. Account owners can delay taking their first RMD until April 1 following the later of the calendar year in which they reach age 72 or, with a workplace retirement plan, when they retire. RMDs are taxable income and may be subject to penalties if not timely taken.

December 12, 2022: The IRS and the US Department of the Treasury (Treasury) announced a new revenue procedure that sets out key processes for manufacturers and sellers of clean vehicles. Revenue Procedure 2022-42 provides guidance on new rules added as part of the Inflation Reduction Act of 2022 on how to enter into a written agreement with the IRS to provide periodic written reports containing specified information related to a manufactured clean vehicle. The revenue procedure also provides the procedures for people selling vehicles to report information to the IRS in order for the vehicle to be eligible for the credit.

December 13, 2022: The IRS urged families and people paying for disability-related expenses to consider using an Achieving a Better Life Experience (ABLE) savings account. ABLE accounts do not affect a person’s eligibility for government assistance programs and can also provide tax advantages.

December 13, 2022: The IRS released Revenue Procedure 2022-43, which sets out the final qualified intermediary withholding agreement (QI agreement) entered into under Section 1.1441-1(e)(5) of the regulations, which begins on January 1, 2023. The QI agreement allows certain people to enter into an agreement with the IRS to simplify their obligations as withholding agents and as payors for amounts paid to their account holders and allows certain people to act as qualified derivatives dealers and assume primary withholding and reporting responsibilities on all dividend equivalent payments they make.

December 14, 2022: The IRS Independent Office of Appeals selected Elizabeth (Liz) [...]

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Weekly IRS Roundup October 31 – November 4, 2022

by McDermott Will & Emery | Nov 7, 2022 | IRS Appeals, IRS Audits, IRS Guidance, Tax Reform, Tax Refunds
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 31, 2022 – November 4, 2022.

October 31, 2022: The IRS released Internal Revenue Bulletin 2022-44, which highlights the following:

Treasury Decision 9966: These final regulations increase the renewal user fee for enrolled retirement plan agents from $67 to $140 and also increase both the enrollment and renewal of enrollment user fees for enrolled agents from $67 to $140.

Proposed Regulations 113068-22: These proposed regulations relate to recordkeeping and reporting requirements for the average income test for purposes of the low-income housing credit.

Revenue Ruling 2022-19: This revenue ruling provides a rule for valuing noncommercial flights on employer-provided aircraft, including the three Standard Industry Fare Level (SIFL) rates: the Unadjusted SIFL Rate, the SIFL Rate Adjusted for PSP Grants, and the SIFL Rate Adjusted for PSP Grants and Promissory Notes.

Treasury Decision 9967: This document contains final and temporary regulations, which set forth guidance on the average income test for purposes of the low-income housing credit.

October 31, 2022: The IRS released COVID Tax Tip 2022-166, announcing that more than nine million people may qualify for tax benefits they did not claim by filing a 2021 federal income tax return. Many of these people may be eligible to claim some or all of the 2021 Recovery Rebate Credit, the Child Tax Credit and the Earned Income Tax Credit, among others, which were expanded last year under the American Rescue Plan Act of 2021 and other legislation.

November 1, 2022: The IRS released COVID Tax Tip 2022-167, alerting taxpayers in areas covered by certain Federal Emergency Management Agency disaster declarations that they may have more time to file their returns and may qualify for penalty relief under Notice 2022-36.

November 2, 2022: The IRS released COVID Tax Tip 2022-168, reminding people to review their tax withholdings to avoid tax surprises, such as a balance due or a larger-than-expected refund.

November 3, 2022: The IRS requested comments on three notices related to different aspects of extensions and enhancements of energy tax benefits in the Inflation Reduction Act of 2022. The IRS hopes that comments will aid the agency in drafting the related guidance items. Feedback should be submitted by December 3, 2022. The notices include:

Notice 2022-56, which requests comments related to the qualified commercial clean vehicles provisions and the alternative fuel vehicle refueling property

Notice 2022-57, which requests comments related to the carbon capture tax credit

Notice 2022-58, which requests comments related to the tax credit for the production of clean hydrogen and the clean fuel production tax credit.

November 3, 2022: The IRS
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Weekly IRS Roundup October 3 – October 7, 2022

by McDermott Will & Emery | Oct 10, 2022 | IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 3, 2022 – October 7, 2022.

October 3, 2022: The IRS released Internal Revenue Bulletin 2022-40, which highlights the following:

Notice 2022-40: This notice provides updates on the corporate bond monthly yield curve and corresponding spot segment rates and the 24-month average segment rates for September 2022. The notice also provides guidance as to interest rates on 30-year Treasury securities and 30-year Treasury weighted average rates.

Notice 2022-39: This notice provides rules related to the Inflation Reduction Act of 2022. Claimants must follow this guidance in order to make a one-time claim for the credit and payment allowable for alternative fuels sold or used during the first, second and third calendar quarters of 2022.

Revenue Procedure 2022-35: This guidance adds Turkey to the list of jurisdictions that the US Department of the Treasury (Treasury) and the IRS have a relevant information exchange agreement with. The agreement relates to information collected under Treas. Reg. §§ 1.6049-8 and 1.6049-4(b)(5), with respect to certain deposit interest paid to residents of the jurisdictions.

Revenue Procedure 2022-36: This ruling provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under Section 842(b) for taxable years beginning in 2021.

Revenue Ruling 2022-18: This ruling provides the federal rates, adjusted federal rates, adjusted federal long-term rate and long-term tax-exempt rate for October 2022.

October 3, 2022: The IRS released Tax Tip 2022-151, providing information on the tax implications when someone is employed by a family member. The list includes married people in business together, children employed by their parents and parents employed by their child.

October 4, 2022: The IRS announced that the IRS Independent Office of Appeals (IRS Appeals) made two revisions to its initial contact letters in response to feedback from taxpayers and practitioners. The revised letters clarify that taxpayers and representatives can choose how they meet with IRS Appeals, whether it be by telephone, video or in-person. In addition, the initial contact letters now include the name and phone number of the IRS Appeals Officer’s manager. For more information, see our post here.

October 4, 2022: The IRS released Tax Tip 2022-152, reminding farmers and ranchers in drought stricken regions that they may have additional time to replace livestock and defer tax on any gains from the forced sales. Notice 2022-43 lists the applicable regions, counties and jurisdictions that are eligible for federal assistance. The relief extends to 44 states, two US territories and two independent nations and generally applies to capital gains realized on sales of livestock held [...]

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