An IRS Letter 105-C Needs a Quarter-by-Quarter Evidence Map Before an Appeal Request
An IRS Letter 105-C ERC disallowance needs a deadline card, a quarter-by-quarter issue map, and indexed support before a tax professional prepares the response or appeal request.
An ERC disallowance response becomes manageable when every tax quarter, stated reason, deadline, source record, and professional-review decision has its own visible row.
If you received IRS Letter 105-C denying all or part of an Employee Retention Credit claim, first authenticate the letter, record the decision date and tax periods, and separate the IRS response window from the separate two-year refund-suit timeline stated in current IRS guidance. Build one issue-and-evidence row per quarter before anyone writes a rebuttal or appeal request.
Part of the complete guide: IRS Notice Small Business Response Guide
The first mistake is treating every quarter as one case. The stated reason, payroll records, government-order analysis, gross-receipts support, aggregation facts, and claim amount can differ by quarter. The second mistake is sending a large folder without an index that connects each document to the reason in the letter.
This is an organization job, not a do-it-yourself eligibility opinion. A qualified tax professional or attorney should decide the legal position, appeal language, Form 907 use, refund-litigation timing, and whether additional filings are required.
The ERC Disallowance Letter Response Organizer Kit gives the team editable deadline, quarter, issue, evidence, cover-note, submission, and follow-up controls when the notice involves several periods or advisers.
What the Letter 105-C control file must contain
| Control row | What to capture | Decision it supports |
|---|---|---|
| Notice identity | Letter number, date, taxpayer name, EIN ending, tax periods, claim amounts, stated reason, and response instructions. | Confirms the team is answering the real authenticated notice. |
| Deadline card | Requested response date, appeal request path, two-year disallowance date, adviser review date, and submission buffer. | Keeps an operational reply date separate from rights that need professional advice. |
| Quarter map | One row per quarter with eligibility position, wage source, health-plan cost, aggregation facts, and claimed amount. | Prevents evidence for one period from being assumed to prove another. |
| Issue map | Each IRS reason, the fact in dispute, controlling record, gap, owner, and adviser question. | Turns a general objection into answerable items. |
| Submission record | Approved response version, indexed exhibits, appeal request, delivery method, proof, IRS reply, and next check. | Preserves what was actually sent and what remains open. |
The IRS currently explains that Letter 105-C states the reason, decision date, appeal rights, and timeframe to file suit. Its Letter 105-C guidance says a disagreeing taxpayer should provide additional support and can request an appeal, while also warning that the two-year timeline continues to matter. Use the current letter and professional advice as controlling; this article does not calculate eligibility or extend a deadline.
The four rules for an auditable response packet
The business mixes quarters, repeats eligibility conclusions, attaches an unlabeled payroll export, and never records which deadline the team is tracking.
Each IRS reason maps to a period, source record, gap, adviser question, indexed exhibit, and approved submission.
The cover-note outline you can copy
Taxpayer: [legal name and masked identifier]
IRS letter: Letter 105-C dated [date]
Tax periods addressed: [quarters]
Requested action: [professional-approved description, including appeal request if applicable]
Issue map: [Exhibit A lists each stated reason and the related period]
Supporting records: [indexed exhibits and what each establishes]
Known gaps or corrections: [facts, not conclusions]
Authorized representative: [name and authority, if applicable]
Submission method and date: [approved channel]
Reply contact and next check: [details]
Use the broader small-business tax notice response guide to authenticate a notice and build the first deadline file. If the issue is a payroll deposit or return mismatch rather than an ERC claim, use the payroll tax notice reconciliation checklist.
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Small business example
A hypothetical employer receives one Letter 105-C covering the second and third quarters of 2021. The letter questions gross-receipts support for one quarter and the qualified-wage calculation for the other. The owner initially puts both quarters into one folder labeled ERC appeal. The payroll lead instead creates two quarter rows, records the exact stated reason and claimed amount for each, links the accounting reports to the first row, and links payroll registers and health-plan records to the second. An adviser finds that one report uses a different comparison period and requests a corrected source export before drafting anything. The example shows why a clean organizer matters; it does not say the claim qualifies or predict an IRS decision.
Letter 105-C response checklist
- Authenticate the complete letter, envelope, sender, taxpayer identity, periods, amounts, and response channel.
- Record the decision date, requested response date, separate two-year date, adviser review date, and internal submission buffer.
- Create one row for every tax quarter covered by the disallowance.
- Copy each stated reason into the issue map without paraphrasing it into a broader complaint.
- Link every factual response to a dated source record and record missing support as a gap.
- Ask the adviser to decide eligibility, appeal, Form 907, power-of-attorney, amended-return, and litigation questions.
- Freeze the approved response and exhibit index before submission.
- Save delivery proof, IRS correspondence, assigned contacts, next checks, and any revised deadline advice.
FAQ: does responding within 30 days replace the two-year deadline?
No. Current IRS guidance discusses an early response or appeal request and a separate two-year period connected to a disallowance. The facts, dates, and protective steps can be consequential. Have a qualified tax professional or attorney read the actual letter and advise on every deadline and available action.
Free version vs. full kit
This article gives you the free version: deadline card, quarter map, issue-to-evidence table, cover-note outline, worked example, and checklist. The full ERC Disallowance Letter Response Organizer Kit adds editable quarter, document, exhibit, adviser-question, submission, and follow-up tools for a live case.
Organize the case with the ERC Disallowance Letter Response Organizer Kit
Related article: Turn a Tax Notice Into a Deadline File
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