TAX SEASON

Bradley Burnett: ERC Trap Threatens Thousands of Taxpayers

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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.

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Ten Tax Issues That Add New Revenue

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Plus four “how much” questions you can put numbers to.

By Ed Mendlowitz
How to Build a Stronger Tax Practice

As you see each tax prep client you should keep a list of additional services you can offer them. Also, continue this list when you review each return.

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I prepare a list of follow-up items during a tax season on my Microsoft Outlook task list. These items are entered as the issue or idea arises. It is simple, quick and very satisfying. The next job will be to make the time to follow up with the client, and do your “good deed.”
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Four Ways to Identify Candidates for Cross-Selling

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https://cpatrendlines.com/2016/06/11/adopt-a-marketing-mindset/

Adopt a marketing mindset.

By Ed Mendlowitz

The average tax return client thinks of accountants as being mainly involved in taxes. Also, an accounting firm’s largest volume of clients is usually for tax return services. Therefore, a good part of the public image of your firm must come from the tax department.

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The tax department must be involved in:

  • strengthening the firm’s brand and name recognition,
  • getting publicity and
  • introducing tax return clients to additional services.

Unfortunately, many accounting firms provide very little guidance or training in this area.

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It’s Time to Start Marketing for Next Tax Season

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Your ideas are fresh now.

By Ed Mendlowitz
Tax Season Opportunity Guide

Marketing takes many forms. Further, many accountants are not trained in marketing. I also know that while most CPAs want more business, they are too busy with what they have to be actively seeking new business. Additionally, marketing can be external, internal or retentive.

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External is where new clients are solicited. That takes effort, ingenuity, time and maybe even some money.
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Tax Season Leaves Accountants Drained, Disappointed

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The 30-point swing: Accountants close the season feeling slightly negative, at minus 1.8, a collapse of more than 30 points.

The Busy Season Barometer Shows Exactly When—and Why.

By CPA Trendlines

After starting near historic highs, sentiment among tax professionals fell more than 30 points by April, as workload, client behavior and system failures overwhelmed expectations.

MORE Busy Season Barometer | Join the survey. Get the results

The 2026 tax season began with confidence.

By December, sentiment among tax professionals had climbed to a positive 29.8—the strongest reading in the CPA Trendlines Busy Season Barometer cycle. A majority expected better conditions. Few anticipated what came next.

By April, that optimism had vanished.

Accountant attitudes closed the season slightly negative, around -1 to -1.8, marking a swing of more than 30 points in four months.

It was one of the sharpest same-season reversals in the Barometer’s 24-year history, and it followed a pattern practitioners have seen before: expectations rising in the fall, then breaking under the weight of the season itself.

The difference in 2026 was the speed—and the causes.

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