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IR-2026-58 generally requires taxpayers to have already responded to Letters 105-C or 106-C.

The Claim

Under Internal Revenue Service news release IR-2026-58, a taxpayer who has not yet responded to Internal Revenue Service Letter 105-C or Letter 106-C is not considered to be waiting for the Internal Revenue Service to consider their response, has not triggered Internal Revenue Service review, and therefore does not meet the first eligibility condition for the streamlined process described in IR-2026-58.

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The Short Version

The release’s eligibility language is best read to require that a response to Letter 105-C or 106-C has already been sent. That means a taxpayer who has not yet responded generally does not meet the first condition for the streamlined Form 907 process in IR-2026-58. The claim overstates one point, however, because the release does not expressly say that no IRS review has been triggered.

Caveats

  • IR-2026-58 supports the eligibility conclusion, but it does not explicitly state that a non-responding taxpayer has "not triggered IRS review."
  • The IRS release does not define every edge case for what counts as a "response" or when a taxpayer is considered to be "waiting."
  • The strongest support comes from IRS primary sources; press-release reposts and non-authoritative summaries add little independent value.

The Receipts

  1. IRS announces new option for certain taxpayers to request more time after ERC claim disallowance

    Internal Revenue Service

  2. If you receive Letter 106-C about the Employee Retention Credit

    Internal Revenue Service

  3. Understanding Letter 105-C, Disallowance of the Employee Retention Credit

    Internal Revenue Service

  4. Understanding your CP320B notice

    Internal Revenue Service

  5. Form 907, Agreement to Extend the Time to Bring Suit

    Internal Revenue Service

  6. 26 U.S. Code § 6532 - Periods of limitation on suits

    Cornell Law School Legal Information Institute

  7. Extending the Statute of Limitations for Disallowed ERC Claims: An Analysis of the New IRS Procedures

    Current Federal Tax Developments

  8. IRS announces new process for extending time to review disallowed ERC claims

    KPMG

  9. New IRS Pathway for Denied ERC Refund Claims

    BDO USA

  10. IRS offers extension option for taxpayers facing ERC claim deadlines

    Journal of Accountancy

+ 2 more sources — see the full list on Lenz

Filed Under

Internal Revenue Service Letter 105-CInternal Revenue Service Letter 106-CIR-2026-58IRS

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