TaxNow’s ERC Headline of the Week: A Post-Thanksgiving ERC Slowdown Without a Sugar Crash

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TaxNow
03 Dec 2025
TaxNow's ERC Headline of the Week Graphic

ERC Trend Recap:

With Thanksgiving shortening the workweek, ERC activity pulled back modestly but predictably. Refund dollars held up well, new audits remained nonexistent, and denials continued to concentrate almost entirely on OBBBA-disqualified quarters. For a holiday-compressed week, this was a steady performance.

In not-so-positive news, the IRS is now closing many correspondence audits issued over the past three months.  In almost all cases, we are observing zero-balance adjustments, suggesting the IRS is closing these audits without approving any ERC or engaging with the taxpayer at all.  Expect a wave of 105Cs with limited explanations to follow suit.

This Week's Scoreboard:

📈 Total Refunds: 122 (vs. 162 last week — down 40)

The short week likely explains most of the drop in unit volume.

📈 Total Dollar Volume: $46.6M (vs. $53.1M last week — down $6.47M)

Dollars held up better than counts, signaling continued movement of larger claims, including several seven-figure claims.

📉 Average Refund: $381,831 (vs. $327,650 last week — up $54,181)

A slight jump, reinforcing that higher-value claims remained in circulation.

📈 Average Days Between Filing and Refund: 624 (vs. 643 last week — down 19 days)

A constructive signal that the IRS continues to work on older claims.

ERC Refund 12-03
ERC Dollar 12-03

IRS Enforcement Round-Up:

New Denials: 123 (vs. 78 last week — up 45)
Still overwhelmingly tied to OBBBA-disqualified quarters, not legacy filings, and likely underreported, as the IRS appears to be using both “Disallowed Claim” and “Additional Tax Assessed” to kill these claims (noting, TaxNow only includes Disallowed Claim in the inventory).
New Audits: 0
New audits remain on hold, butwe are beginning to see a wave of “closed” audits on transcripts showing$0.00 values, suggesting the IRS is beginning to move on the significant inventory of correspondence audits, and not in a positive direction. TaxNow’s prediction that these correspondence audits would be a backdoor strategy to summarily deny ERC claims is starting to come to fruition 🙁.

Fresh Off The Press:

It was a quiet week across ERC and IRS news, which is typical around Thanksgiving. No meaningful legislative, funding, or enforcement developments materially affected ERC processing.

TaxNow's Take:

While headline refund volume softened with the holiday, the underlying data continues to reinforce what we’ve been tracking for months: legacy ERC claims are still moving, average refund sizes remain resilient, and enforcement pressure is being applied narrowly through targeted disallowances tied to OBBBA-affected quarters. At the same time, the emerging pattern of silent correspondence audit closures with zero-dollar outcomes is a developing risk area that taxpayers and practitioners should monitor closely. As always, TaxNow will continue to track transcript-level activity in real time and flag meaningful shifts as they develop.

Signing off!

Kenny Dettman, CPA

Disclaimer: *𝘋𝘢𝘵𝘢 𝘴𝘦𝘵 𝘪𝘴 𝘧𝘳𝘰𝘮 𝘢𝘱𝘱𝘳𝘰𝘹𝘪𝘮𝘢𝘵𝘦𝘭𝘺 14,000 𝘣𝘶𝘴𝘪𝘯𝘦𝘴𝘴𝘦𝘴 𝘵𝘳𝘢𝘤𝘬𝘪𝘯𝘨 𝘌𝘙𝘊*

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