ExFed Tax, LLC

09/25/2026

If you haven’t filed tax returns for several years, silence from the IRS is not the same as safety. It may simply mean your case is waiting for resources.

A new TIGTA report found that 38,824 high-priority nonfiler cases remained at the first-notice stage, representing an estimated $15.7 billion in potential assessments. Thousands more were still waiting to be assigned.

A backlog is still a backlog—not forgiveness.

If the IRS prepares a substitute for return, it generally works from income reported by employers, banks, brokers, and payment processors. It may not have your business expenses, basis, deductions, credits, dependents, or other favorable facts. Apparently, complimentary tax preparation was not part of the federal budget.

Our latest article explains:

• What the TIGTA report found
• How IRS substitute returns work
• The difference between the 30-day and 90-day letters
• Why unfiled returns do not simply age out
• What to do before enforcement begins

It is usually less expensive to prepare accurate returns now than to hire someone later to undo the returns the IRS prepared without you.

Read the full article:
https://www.exfedtax.com/post/irs-nonfiler-enforcement-unfiled-tax-returns

We left the IRS. You’re welcome.

TIGTA found thousands of high-priority nonfiler cases stalled—but the IRS is moving them forward. Here is why waiting can turn return preparation into an expensive tax controversy.

09/16/2026

“I’ll deal with the unfiled returns when the IRS contacts me” sounds inexpensive.

It usually is not.

Preparing accurate delinquent returns is ordinarily cheaper than defending substitute-for-return assessments, reconstructing the record under deadline pressure, and trying to preserve rights after notices have gone unanswered.

If you have not filed in years, now is the time to get in front of it.

Call EXFEDTax: 832-305-6080.

TIGTA found thousands of high-priority nonfiler cases stalled—but the IRS is moving them forward. Here is why waiting can turn return preparation into an expensive tax controversy.

09/14/2026

A taxpayer can give the IRS 3,000 pages and seven books—and still arrive at Appeals with a file thin enough to make the evidence look imaginary.

Then, in PAM, the taxpayer is told: “You should have told us about those documents.” - Well, they did.

My latest Administrative Record article examines where that hazard belongs under RRA 98, AJAC, and Appeals’ own manual—and why PAM cannot meaningfully mediate a record the IRS failed to preserve, transmit, or analyze.

We left the IRS. You’re welcome.

When IRS files omit ERC or R&D evidence, Appeals cannot blame the taxpayer. See how AJAC, RRA 98, RGS limits, and PAM procedures apply.

09/09/2026

If you haven’t filed tax returns in years, the least expensive time to address it is usually before the IRS files for you.

An IRS substitute for return may not include deductions, credits, elections, or other facts that a properly prepared return would reflect. Then come the notices: a proposed assessment, an opportunity for administrative review, and potentially a statutory notice of deficiency with a 90-day Tax Court deadline.

Ignore the process and the proposed liability can become an assessment.

There is another problem: when no return is filed, the normal assessment statute of limitations generally does not begin. The file can remain available to the IRS much later—sometimes much, much later.

Read the article. If this sounds familiar, call EXFEDTax before the IRS chooses the timetable.

832-305-6080

We left the IRS. You’re welcome.

TIGTA found thousands of high-priority nonfiler cases stalled—but the IRS is moving them forward. Here is why waiting can turn return preparation into an expensive tax controversy.

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