ERC Claim Denied: Appealing an IRS Letter 105-C, the Deadlines That Matter, and When a Refund Suit Is the Better Path

Receiving an IRS Letter 105-C after waiting months or years for an Employee Retention Credit refund changes the situation immediately. The claim is no longer merely pending. The IRS has formally disallowed it, and an ERC claim denied appeal becomes a deadline-sensitive tax controversy matter. Two procedural tracks now matter....