Webinar: Employee Retention Credit Disputes: Navigating IRS Form 907, Appeals, and Refund Litigation by ALFi

As IRS scrutiny of Employee Retention Credit (ERC) claims intensifies, tax professionals need a clear roadmap for managing claims that stall, get denied, or head toward litigation. This webinar walks through the practical mechanics of extending your claim's window with Form 907, building a strong administrative appeal, and evaluating whether refund litigation is the right next step.

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Presenters

Justin Elanjian

Tax Managing Director

Justin Elanjian is a highly accomplished Managing Director at Frost Law. With over 15 years of experience as a consultant and accountant, Justin brings a wealth of knowledge and expertise to the firm.

Justin specializes in working with businesses of all types and sizes on government program-related economic assistance, including the CARES Act and other pandemic-related relief including, but not limited to, the Employee Retention Credit (ERC) and the Paycheck Protection Program (PPP). Specifically, he works with businesses to obtain and retain COVID relief funds they’re entitled to.

Justin regularly writes and presents on ERC. He is often featured in publications, podcasts, webinars, and other periodicals, including Bloomberg, TaxNotes, Forbes, the Wall Street Journal and the American Business Journals, in addition to numerous trade associations.

Peter Haukebo

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

About

Program Field of Study: Taxes
Program Level: Basic
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None

What attendees will:

- Assess the purpose and function of IRS Form 907 (Agreement to Extend the Time to Bring Suit) and when it's appropriate to use it in an ERC claim dispute
- Identify key deadlines and statute of limitations considerations under IRC § 6532(a), and how executing Form 907 affects a client's options
- Discuss best practices for preparing a persuasive administrative appeal, including documentation, protest letters, and IRS Office of Appeals procedures
- Evaluate strategic considerations for deciding between continuing the appeals process and pursuing refund litigation in federal court
- Outline the refund litigation process, including jurisdictional requirements, venue selection (District Court vs. Court of Federal Claims), and typical timelines
- Discuss pitfalls that can jeopardize a claim's viability at each stage, from initial denial through litigation
- Review practical tips for managing client expectations around timing, costs, and likelihood of success at each decision point