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.
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.
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.
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.
Quarter-over-quarter gross receipts decline of at least 20% (2020) or 80% (2021) verified against original payroll records and any amended returns.
Full or partial suspension of operations due to a government order, with documented evidence of the order and its impact on the business.
Business began after February 15, 2020, with average annual gross receipts under $1 million — verified against formation documents and tax returns.
The IRS assessment window for Q3/Q4 2021 claims is six years from the date of filing, computed deterministically — never estimated.
Wages and health plan expenses must be properly allocated to the eligible quarter, with supporting payroll records and health plan documentation.
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.
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.
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.
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.
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.
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.
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.
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 deliverable is completeness itself — every eligibility test and substantiation element accounted for or explicitly exception-coded. Nothing is left implicit.
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a statutory requirement.
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.
Simple, predictable, and aligned with a documentation standard — not a percentage of any credit or recovery.
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.