Bradley Burnett: ERC Trap Threatens Thousands of Taxpayers

Bradley Burnett

While cases stall, the right to sue could expire.

By CPA Trendlines Research

Thousands of business taxpayers still battling Employee Retention Credit disallowances could lose their right to sue the IRS in 2026 because the two-year refund-suit deadline keeps running while cases sit in IRS examination or Appeals, a risk tax attorney Bradley Burnett calls part of a “colossal mess” of statute traps, litigation risks and unresolved audits.

The National Taxpayer Advocate estimates roughly 28,000 taxpayers may be affected, prompting the IRS to roll out a special Form 907 extension process for certain ERC claimants approaching the deadline.

CPE WEBINAR

Covid ERC in 2026: Picking Up the Pieces: Which Are Ticking Time Bombs?

With Bradley Burnett, J.D., LL.M.

Thursday, June 18, 1-4 p.m. ET

Register | Learn more

“What is left … a colossal mess,” Burnett tells CPA Trendlines Academy attendees. “Some of those broken pieces out there may be time bombs.”

The filing window has closed. The refund fights have not.

READ MORE →

Unlock Accelerated Growth with 21 Questions

Business hand holding hot chart in crystal ball

Don’t stay attached to traditional models that no longer suit you.

By Domenick J. Esposito
8 Steps to Great

When it comes to growth, two of my core beliefs are:

  • size matters, and
  • service line diversification (the professional services model) is better than the traditional accounting firm model.

MORE by Domenick J. Esposito
GoProCPA.comExclusively for PRO Members. Log in here or upgrade to PRO today.

 

The proof is in the pudding.

READ MORE →

What Happens to Your Firm If You Die? Seriously.


Get the free practice-continuation toolkit.

By Ed Mendlowitz
Call Me Before You Do Anything: The Art of Accounting

One morning, my wife and I were having breakfast, and she asked me, “What do I do if you and Peter get killed?”

DOWNLOAD: Practice Continuation in Event of a Death or Disability Sample Agreement and Letter of Instruction, Prepared by Ed Mendlowitz

This was a Friday, and Peter Weitsen and I were flying together on Sunday to a conference in Palm Springs. My response to these questions was typical: “Don’t bother me. Nothing will happen!”
READ MORE →