Frost Law Urges IRS to Extend ERC Appeal Deadlines Amid Backlog Crisis
Event summary
- Frost Law calls on IRS to expedite Form 907 use to extend ERC appeal deadlines, citing backlog risks.
- 28,000 ERC denials face two-year expiration window starting this summer; 300+ already lapsed.
- IRS denied/reversed ~214,000 ERC claims with frequent communication failures on appeal rights.
- Taxpayer Advocate report highlights 30% of denial letters omit critical Form 907 information.
The big picture
The ERC program's complexity has created systemic delays, with the IRS struggling to process claims efficiently. Frost Law's push highlights broader tensions between taxpayer rights and administrative capacity in pandemic-era relief programs. The scale of denied claims (214,000) suggests systemic issues that could trigger regulatory reforms or judicial interventions.
What we're watching
- Regulatory Response
- Whether IRS will adopt Form 907 expediting to prevent mass refund expirations.
- Litigation Wave
- The pace at which taxpayers pursue legal action as deadlines approach.
- Appeals Backlog
- How IRS prioritization efforts impact resolution timelines for pending cases.