If you claimed the employee retention credit (ERC) and then received Letter 105-C, Disallowance of the Employee Retention Credit, the IRS says you have 2 years from the date of the letter to file a lawsuit. Requesting an appeal of an adverse determination does not extend the 2-year period. If you disagree with the IRS disallowance of your credit, follow the steps outlined by the IRS, such as submitting an explanation and certain documentation. #IdeaoftheDay