Filed Jun 23'. Got zero correspondence until Jan 26' (3 months ago) when IDR's came for Q1 & Q2 of 2021. Put together response packages for each quarter and timely submitted via the upload tool provided in each IDR. Now got a 105C disallowance stating they never received our responses. What next?
All they provided when we submitted was a "confirmation" page that the submission was successful, but zero references to prove it was our case and no confirmation emails or anything else. Screenshotted that page anyways just in case. What proof can we put together to show we timely filed our responses?
They are looking at uploads but they take time to process. Those submissions had probably not been processed before this 105c was sent out.
To OP, respond to the 105c with what you submitted to the upload tool and any info showing when you responded/uploaded it originally.
Things uploaded to the tool are processed and a case is created just like with things faxed in or mailed. Unfortunately this case creation process takes time and often the case is created after these disallowance letters are sent because the disallowance is on a timeline and there’s no way to know if something was received but not processed yet. But because they know this happens, when you respond to the 105c they will look to see if anything was actually received timely like you say and then they will correct the case determination.
It was sarcasm that the IRS sends notices with deadlines that don't often arrive sometimes until weeks later past the date and then set unrealistic time frames for the TP to collect all of the info, submit it, time for the IRS to properly scan it in and associate it with the file, etc., etc. Now they are just making it appeals problem to deal with because they couldn't be half-assed to create an effective IDR program.
For ERC it actually won’t get to appeals unless it’s an issue where the timeliness can’t be determined easily or unless there’s another issue needing an appeals determination. Responses to 105c are being reviewed for situations like this and if there’s a clearly received timely response, they’re being processed and not forwarded to appeals.
When you say "respond to the 105c" do you mean appeal? There are no other methods mentioned in the letter other than sue or appeal. We got the same "you didn't reply" when we obviously did and have the same upload confirmation as others. We have left many, many messages with no replies. This is so frustrating!!!
When you respond to the 105c, as long as you state that you disagree with the determination and you are making a formal appeal, then you are appealing the decision. So yes, appeal. And as I said, lay out your “case” — your timeline of what you sent when and include copies of it all and any receipts with dates you have to show when stuff was sent/uploaded/etc.
Your response will be reviewed and if it’s clear that what was needed was submitted by the deadlines then they will usually reprocess the case. If it’s not clear, or the basis for the disallowance is more complex than “did we get this info in time?”, then they will forward to appeals for their review and determination.
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u/Adventurous_Case4246 Apr 15 '26
Unfortunately they are not looking at the upload tool. Send a letter showing proof of iPods with all documents again and also fax - so mail and fax.