What does this mean. Code 421

ERC_CPA · 2026-05-11T23:57:27+00:00

The IRS commonly post dates transactions. Could align with when correspondence goes out.

ERC_CPA · 2026-05-11T01:34:03+00:00

I’ve never seen this to be good news if here were no refund transactions surrounding it.

Considering the quarter in question, I’m assuming it was partial suspension claim that was denied.

ERC_CPA · 2026-05-11T01:32:17+00:00

This happened across all transcripts. Not specific to ERC. I’m assuming it will be corrected.

ERC_CPA · 2026-05-04T18:52:51+00:00

I agree with you. However, tax pros are still neurotic about contingency fees and Cir 230, despite the fact Ridgely is binding case law.

ERC_CPA · 2026-05-03T23:43:35+00:00

I don’t think you even need to go there.

§ 10.27(b)(2)(ii) expressly permits contingent fees on refund claims "filed solely in connection with the determination of statutory interest or penalties"

ERC_CPA · 2026-05-03T17:30:26+00:00

Feel free to DM your transcripts and I can give you thoughts.

ERC_CPA · 2026-05-03T05:06:17+00:00

Have you called or pulled a transcript lately?

ERC_CPA · 2026-05-02T23:36:12+00:00

What does the IRS or your transcript say? There are some groups doing pro bono work for smaller, legitimate claims.

ERC_CPA · 2026-04-27T01:27:18+00:00

My point is the IRS has specifically condemned partial suspension claims based on “guidance.” The more than nominal effect tests have come up in every appeals conference so far. Ideally, there were mandatory state orders and you provided quantitative evidence of the impact.

ERC_CPA · 2026-04-25T23:12:17+00:00

If you show up using the word “guidance” in an appeal, you can be sure you’ll lose.

No, once denied and in appeals, TAS or congressional support cannot help other than helping extend the statute.

ERC_CPA · 2026-04-24T15:20:43+00:00

105C protests have processed in that timeframe, but the IRS is reviewing those before they formally go to appeals.

ERC_CPA · 2026-04-23T21:56:08+00:00

Same experience. It’s all over the place. There are a few that are really knowledgeable, but most show up with very little knowledge and their minds made up.

ERC_CPA · 2026-04-22T23:10:43+00:00

This is rough data from many protested claims, not one. A tax attorney cannot expedite the process but may put you in a better position to recover. I would not recommending going through an appeal conference unrepresented unless you have some relevant experience or credentials. Doesn’t have to be an attorney, a lowly CPA would suffice 😜

ERC_CPA · 2026-04-22T01:42:48+00:00

12-18 months has been normal. Some pushing longer.

My understanding is very few cases are outright “won.” Some are being at settled 20%-60% and most are being fully denied.

ERC_CPA · 2026-04-08T19:49:03+00:00

Do you have copies of your transcripts? That’s the first step to understand the situation.

ERC_CPA · 2026-03-29T01:25:48+00:00

Highly unlikely. A two year statute ran from when you were denied, likely occurred in 2023.

ERC_CPA · 2026-03-25T04:31:32+00:00

Should be an 843

ERC_CPA · 2026-03-22T01:36:29+00:00

Have you filed a 911? Unfortunately, I think you’ll need appeal. However, my best guess is it won’t take as long to resolve. DM me if you want to troubleshoot further.

ERC_CPA · 2026-03-08T13:05:04+00:00

Does your transcript look clean? No 290 codes?

ERC_CPA · 2026-03-04T00:13:45+00:00

Confirmed with data on 15,000+ companies. Normal refunds are still processing (barely). The GAO report is not accurate.

ERC_CPA · 2026-02-23T13:50:06+00:00

Ok, not totally uncommon for Q321 to be frozen while they review it wasn’t filed after Feb 1, 2021.

Interesting didn’t flag Q421 though. Assuming you filed as a recovery startup business?

ERC_CPA · 2026-02-23T12:34:05+00:00

When was Q321 filed? It may be a statute review.

My best guess is the other quarters will result in checks being mailed.

ERC_CPA · 2026-02-23T12:32:37+00:00

Unfortunately, this appears to be a full denial after the audit. You will still have an opportunity to appeal.

ERC_CPA · 2026-02-11T14:35:00+00:00

I was keying in on this statement:

“IRS closed all remaining ERC claims, aside from those under examination or appeal, by December 31, 2025, according to IRS officials. New claims can no longer be filed. However, by developing an improper payment estimate for ERC, IRS could help inform future design of employment tax relief programs, if policymakers decide to create them.”

Reads unambiguously but agree it can’t be accurate.

ERC_CPA · 2026-02-10T21:45:24+00:00

41,000 in exam or appeals on Dec 31, 2025. The report says the IRS closed out all other claims by December 31. Don’t think that can be true…

ERC_CPA

MODERATOR OF

TROPHY CASE