§328.17 Every subsection, on every pack — verified, not assumed

The most rigorous ERC audit-defense engine a small business can deploy.

SixYearShield assembles a documentation-complete audit-defense and resolution pack — every eligibility test re-analyzed, every IRS notice parsed, every response drafted, and every deadline calendared — checked against the IRS's own published risk-scoring red flags and the OBBBA's six-year statute before a Circular 230 practitioner releases it.

Every ERC eligibility test re-analyzedIRS notice parsing & response draftingDHSMV · USCG · UCC · judgment lien searchesCircular 230 practitioner review & signature5-business-day SLA
Why audits fail

A single missing element can trigger a full clawback.

A small business that received an ERC refund between 2020 and 2024 now faces a six-year IRS audit window under the One, Big, Beautiful Bill Act. Miss one eligibility test, overlook a government-order suspension nuance, or fail to respond to a 105-C disallowance letter within the deadline — and the IRS can claw back the entire credit, plus a 20% penalty.

Most businesses ran their original claim with a promoter or a CPA who has since moved on. The statute has not been re-read since the claim was filed. That is exactly where audit-defense gaps hide.

SixYearShield exists to close that gap with a single, exhaustive standard applied identically to every file.

84,000+
disallowance letters already mailed by the IRS
The benchmark

Measured against the IRS's own risk-scoring criteria — test by test.

We do not summarize the law and hope. Every pack is scored against a versioned rule pack tied to the exact text of the OBBBA, IRS Notice 2021-20, and the IRS's published AI-driven risk-scoring red flags. These are the provisions each pack is held to.

IRC §3134

Gross-receipts-decline test

Quarter-over-quarter gross receipts decline of at least 20% (2020) or 80% (2021) verified against original payroll records and any amended returns.

IRC §3134(c)(2)(A)

Government-order-suspension test

Full or partial suspension of operations due to a government order, with documented evidence of the order and its impact on the business.

IRC §3134(c)(2)(B)

Recovery-startup-business test

Business began after February 15, 2020, with average annual gross receipts under $1 million — verified against formation documents and tax returns.

OBBBA §101

Six-year statute of limitations

The IRS assessment window for Q3/Q4 2021 claims is six years from the date of filing, computed deterministically — never estimated.

IRS Notice 2021-20

Qualified wage & health plan cost substantiation

Wages and health plan expenses must be properly allocated to the eligible quarter, with supporting payroll records and health plan documentation.

IRC §6651

20% erroneous-refund-claim penalty

If the claim is found to be erroneous, a 20% penalty applies. Our substantiation pack is designed to minimize this risk by ensuring every element is documented.

How a pack is built

Intake to practitioner release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A Circular 230-credentialed practitioner reviews and signs every release. That order is never reversed.

01

Exposure Scan

Upload the original ERC claim, payroll records, and any IRS notice received. We return a free completeness read: which eligibility tests and substantiation elements you already have, and which are missing.

02

Evidence & document assembly

As your authorized clerical agent, we gather payroll records, government orders, formation documents, and any prior correspondence with the IRS, and build a substantiation evidence log.

03

Grounded drafting

The response letter or substantiation package is drafted from your validated data and the IRS rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

Eligibility tests are re-analyzed against the original claim; the six-year window is verified; the evidence checklist is resolved; SCRA is screened. Any failure blocks release.

05

Practitioner review & signature

A Circular 230-credentialed enrolled agent, CPA, or attorney reviews the exception queue and signs the release. High-value or complex cases route to attorney review first.

06

Delivery

You receive the pack: response letter, substantiation package, evidence log, deadline calendar, and filing instructions — ready for the practitioner to submit to the IRS.

The bar we hold

Rigor you can measure.

100%
Practitioner-reviewed
No pack ships without a Circular 230 practitioner signature.
5 days
Standard SLA
From complete intake to released pack.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
4
Eligibility tests re-analyzed
Gross-receipts-decline, government-order-suspension, recovery-startup-business, and qualified-wage substantiation.
Why SixYearShield

Built to be the most thorough option a small business has.

Documentation-complete, by design

The deliverable is completeness itself — every eligibility test and substantiation element accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a statutory requirement.

In its lane, on purpose

We prepare documentation and run searches as your clerical agent. We never contact the IRS directly, give legal advice, or represent you before the IRS — that is the practitioner's role.

Engagement

Flat fee, per released pack. No contingency, ever.

Simple, predictable, and aligned with a documentation standard — not a percentage of any credit or recovery.

  • A free Exposure Scan before you commit — see exactly what is missing.
  • One flat fee per released Audit Defense Pack; disclosed pass-through search fees.
  • Optional fixed-fee attorney review for high-value or complex cases.
  • Optional six-year monitoring subscription for ongoing IRS notice tracking and deadline calendaring.
FAQ

Questions, answered precisely.

Is SixYearShield a law firm?
No. SixYearShield, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you before the IRS. A Circular 230-credentialed practitioner reviews and signs every submission.
Do you contact the IRS or represent me?
Never. SixYearShield is not a representative and does not contact the IRS on your behalf. The practitioner of record remains the party responsible for all submissions and representation.
What makes a pack 'complete'?
Completeness is defined by the statute: all four eligibility tests re-analyzed, the six-year window verified, the evidence checklist resolved, and SCRA screened. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a practitioner-released pack. The free Exposure Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released pack, plus disclosed pass-through search costs. No contingency and no percentage of any credit or recovery.

See what's missing before the IRS does.

Start with a free Exposure Scan. Send your original ERC claim, payroll records, and any IRS notice and we'll return a completeness read against every eligibility test and substantiation requirement.

Documentation-completeness service · not legal advice · the practitioner submits every response.