ExFed Tax, LLC

09/03/2026

Our monthly highlights

The IRS Says Taxpayers Can Get More Done Online. The Hard Cases Still Go Offline. The IRS is right about one thing: its online accounts are more useful than they were a few years ago. Taxpayers can view balances, make payments, pull transcripts, check refund status, retrieve some notices, and approv...

09/03/2026

Status 12 Is Not a Developed Record: How ERC Letter 105-C Cases Reach PAM Thin is now available.

It examines how an AIMS status code and Letter 105-C facilitate the movement of ERC cases to Appeals regardless of whether the IRS reviewed the books and records to develop the merits. The analysis reviews Appeals new-information procedures and requirements for PAM readiness.

Administrative codes dictate the flow of paper.

We left the IRS. You’re welcome.

https://www.exfedtax.com/post/erc-letter-105c-status-12-thin-exam-file-pam

09/01/2026

The IRS says taxpayers and tax professionals can resolve many common tax matters quickly online. The tools are real. The record also shows what the release does not measure: eligibility, identity-verification success, handoffs to other channels, and time to final case resolution.

In this week’s Administrative Record, I separate what IRS online accounts can complete from what still requires a human case function—and why practitioners must continue to protect deadlines even when a portal shows activity.

Read: https://www.exfedtax.com/post/irs-online-accounts-what-they-cant-resolve

What the IRS said. What the record shows.

08/26/2026

ERC and Research Credit Mediation: What Makes These Cases Settle in IRS Appeals examines the components of successful mediation for specific tax credits.

We have successfully mediated numerous ERC and research credit matters. Fact-heavy cases require a mediation-ready record and the presence of the right decision-makers to reach a resolution. Data integrity is foundational to tax procedure.

This publication does not identify specific clients, settlement terms, or proprietary firm strategies.

https://www.exfedtax.com/post/erc-research-credit-post-appeals-mediation

We left the IRS. You’re welcome.

08/23/2026

The IRS headline says “abuse by illegal aliens.” The proposed regulations say something more complicated.

The rule would add a PRWORA immigration-status test to the refunded portions of four credits. That affected class can include lawfully present nonimmigrants—not only people who are unlawfully present. And Treasury says it has no direct data identifying which claimants have PRWORA-qualified status.

We broke down what the proposal actually does, what it does not do, how SSNs and ITINs fit in, the special rule for joint returns, and why the first filing date may control the outcome.

Read The Administrative Record: https://www.exfedtax.com/post/what-the-irs-called-abuse-by-illegal-aliens-is-really-a-new-refundable-credit-status-test

08/19/2026

Selecting the appropriate IRS alternative dispute resolution program involves a complex analysis of jurisdiction and timing. Our new article outlines the strategic distinctions between Fast Track, Early Referral, RAP, PAM, and Collection mediation to assist practitioners in case management.

These programs are not interchangeable; their utility depends on the current stage of the dispute and the preservation of taxpayer rights following a failed mediation. It is a map for those who prefer their tax disputes resolved rather than indefinitely marinating in the federal bureaucracy.

We left the IRS. You’re welcome.

https://www.exfedtax.com/post/which-irs-adr-program-jurisdiction-timing-map

05/11/2026

Not every IRS dispute needs to become a lawsuit.

The IRS Post Appeals Mediation Program gives taxpayers and the IRS a meaningful opportunity to resolve difficult issues in a structured, professional forum before litigation becomes the next step.

Independent mediation matters because it brings neutrality, accountability, and focus to the discussion. A strong mediator helps both sides evaluate the facts, the law, and the hazards of litigation in a way that keeps the process productive and resolution-oriented.

I have recently participated in several IRS Post Appeals Mediations that reached settlement. In each case, the common thread was the same: when both sides come prepared, professional, and willing to engage seriously, mediation can work.

For taxpayers, PAM can help avoid the time, cost, and uncertainty of litigation. For the IRS, it supports efficient case resolution and sound tax administration. For everyone involved, it creates a forum where the actual strengths, weaknesses, and risks of the case can be addressed directly.

If you are involved in a tax controversy and need an independent mediator, EXFEDTax™ can help.

Schedule a consultation today. https://wix.to/habAwWX

04/29/2026

Ever wonder what happens to tax people after the deadline passes? Well at EXFED, it looks like the boss is on vacation! 🥳🥳😂😇