This week looked…uneventful on the surface. That said, there are a few undercurrents worth paying attention to.
We continue to hear mixed signals on PEO-related claims. There have been some indications of movement, but those are offset by ongoing anecdotes of extremely long wait times for certain PEO clients, some stretching well beyond what would seem reasonable even in the current environment. No clear pattern yet, but it does raise questions around where delays are occurring—whether at the PEO level, in the underlying filing mechanics, or elsewhere in the process. None of the potential explanations are particularly comforting.
And notably, audit activity remains…absent. No new audits this month, and nothing since early April. At some point, the absence starts to look intentional. Are we out of the woods with ERC audits? Or has the attention shifted to PEO claims?
Your guess is as good as mine…
Total Refunds: 91 (vs. 93 — down 2 / -2%)
Total Dollar Volume: $7.08M (vs. $12.56M — down $5.48M / -44%)
Average Refund: $77,810 (vs. $135,116 — down ~$57K / -42%)
Average Days from Filing to Refund: 6 724 (vs. 636 — up 88 days
Denials: 7 (vs. 17 — down 10)
New Audits: 0 (no change; none since early April)
Last week’s announcement around “streamlined” Form 907 submissions was positioned as a meaningful improvement.
So far, there’s little to show for it.
We haven’t seen a noticeable uptick in activity, acknowledgments, or downstream notices tied to Form 907s submitted through normal, non-DUT channels.
For now, the practical takeaway hasn’t changed: submission alone is not enough. These still require active monitoring, follow-up, and possible interventions by the Taxpayer Advocate Service.
One development that’s easy to miss: we’re seeing an increase in TC 971 (Notice Issued) on accounts where ERC refunds were already approved and paid.
It’s not yet clear what’s driving this.
Could be administrative. Could be follow-up compliance. Could be the early stages of something more coordinated.
At this point, it’s just a pattern worth flagging, not one we can confidently interpret.
Not much changed this week, but that may be the point.
The “streamlined” 907 process hasn’t translated into observable results. PEO movement remains inconsistent. And audit activity has effectively disappeared—for now.
Meanwhile, subtle signals like TC 971 notices on previously paid claims are starting to show up without clear explanation.
ERC isn’t accelerating. It’s not unwinding cleanly either.
It’s just…lingering.
Disclaimer: *𝘋𝘢𝘵𝘢 𝘴𝘦𝘵 𝘪𝘴 𝘧𝘳𝘰𝘮 𝘢𝘱𝘱𝘳𝘰𝘹𝘪𝘮𝘢𝘵𝘦𝘭𝘺 15,000 𝘣𝘶𝘴𝘪𝘯𝘦𝘴𝘴𝘦𝘴 𝘵𝘳𝘢𝘤𝘬𝘪𝘯𝘨 𝘌𝘙𝘊*
