Webinar: ERC Endgame: Appeals, Refund Litigation, and What's Next by ALFi

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Presenters

Peter Haukebo

Partner

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.

Rebecca Sheppard

Partner

Rebecca Sheppard is a Partner at Frost Law with extensive experience representing clients before the IRS and state taxing authorities. She advises on audits, appeals, and tax litigation, focusing on employment tax and the Employee Retention Credit. Rebecca is known for her practical, innovative approach to controversy work and her ability to translate complex tax issues into actionable guidance for practitioners. She regularly speaks on tax procedure and controversy topics to professional audiences. She is a member of the Maryland State Bar Association’s Taxation Section Council.

About

Program Field of Study: Taxes | Federal Tax Law Topics/Federal Tax Related Matters
Program Level: Basic
Who Should Attend: CPAs, EAs, attorneys, tax preparers, small business owners
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00042-26-O

ERC claims are scattered across compliance, examination, Appeals, mediation, and litigation, and the backlog moves unevenly rather than on one predictable timeline. This session covers where claims currently stand and what is actually moving, the issues arising at each stage of Appeals, and a refund-litigation update on when filing suit makes sense. It then turns to Post-Appeals Mediation, covering what to gather beforehand and how to frame the submission. Attendees will leave able to place a claim within the pipeline, anticipate what Appeals requires, decide when litigation is worth filing, and prepare a mediation request built to succeed.

Agenda

Explain where ERC claims currently stand in IRS processing, including the status of the claim backlog and what is moving
Identify the key issues in ERC appeals and what to expect at each stage
Examine the recent refund litigation update discussing recent cases and when it makes sense to file suit
Demonstrate how to respond effectively to a PAM, including what to gather and how to frame the response