15-day B-Notice mailing clock
First B-Notice must be mailed within 15 business days of the CP2100 notice date; second B-Notice within 30 days if no response. Clock verified deterministically.
The most rigorous B-Notice & backup-withholding compliance pack a mid-market AP team can deploy.
Our engine absorbs the entire CP2100 lifecycle — notice parsing, payee matching, first/second B-Notice generation, W-9 solicitation, 24% backup-withholding activation, Form 945 filing, and 972CG penalty-defense documentation — checked against the IRC and Treas. Regs. before a licensed reviewer releases it.
Every clock under IRC §§6721, 6722, 3406First & second B-Notice elements, gate-checkedIRS Pub 1281 & Pub 1586 complianceLicensed reviewer release on every pack5-business-day SLA
Why compliance fails
A single missed deadline can trigger uncapped penalties.
Twice a year — October and April — the IRS mails CP2100 / CP2100A notices to payers whose 1099 filings contain name/TIN mismatches. Each notice starts a brutal set of clocks: 15 business days to mail B-Notices to affected payees, and backup withholding at 24% must begin no later than 30 business days after the notice if the payee does not certify a corrected TIN. Miss the correction path and the IRS later issues 972CG proposed-penalty notices — 45 days to respond — with per-form penalties of roughly $60–$340 and up to ~$680 per form for intentional disregard, with no cap.
Most mid-market AP teams run this by hand, from memory, once or twice a year. The operational grind — decoding the notice file, matching payees, generating compliant first vs. second B-Notice packets, chasing W-9s, flipping backup withholding on and off, filing Form 945, and assembling a reasonable-cause defense — is manual, time-boxed, and error-prone. That is exactly where compliance gaps hide.
Our engine exists to close that gap with a single, exhaustive standard applied identically to every file.
15 / 30 / 45
day clocks for B-Notice, withholding, and 972CG response
The benchmark
Measured against the letter of the IRC and Treas. Regs. — subsection by subsection.
We do not summarize the law and hope. Every pack is scored against a versioned rule pack tied to the exact text of IRC §§6721, 6722, 3406 and Treas. Reg. §301.6724-1. These are the provisions each pack is held to.
24% backup-withholding trigger
Backup withholding must begin no later than 30 business days after the CP2100 notice if the payee has not certified a corrected TIN. Activation and cessation dates computed per statute.
First & second B-Notice content
Each B-Notice includes the required IRS language, payee name/TIN, response deadline, and consequences of non-response — per Pub 1281 and Pub 1586.
Reasonable-cause defense for 972CG
Documentation for penalty abatement under Treas. Reg. §301.6724-1, including significant compliance history, mitigating facts, and corrective actions.
Form 945 filing
Annual Form 945 for backup withholding reported and reconciled; quarterly deposit schedule verified.
Penalty exposure calculation
Per-form penalty exposure computed at $60–$340 per form, with intentional disregard up to $680 per form, no cap. Exposure report included in every pack.
How a pack is built
Intake to licensed reviewer 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 licensed reviewer (CPA or EA) signs every release. That order is never reversed.
01
CP2100 Exposure Scan
Upload the IRS notice file and payee master. We return a free compliance read: which clocks are running, which payees are affected, and what actions are missing.
02
Notice parsing & payee matching
We parse the CP2100/CP2100A extract, normalize payee names/TINs against your master data, and flag mismatches for resolution.
03
Grounded drafting
First and second B-Notice letters are drafted from validated data and the IRC rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic compliance gates
Mailing clocks are verified; backup-withholding trigger dates are computed; W-9 solicitation is tracked; penalty exposure is calculated. Any failure blocks release.
05
Licensed reviewer release
A CPA or EA reviews the exception queue and signs the release. High-exposure or complex cases route to attorney review first.
06
Delivery
You receive the pack: B-Notice letters, payee matrix, evidence log, mailing checklist, certified-mail packet with labels, backup-withholding schedule, Form 945 draft, and 972CG defense documentation — ready for the payer to send under its own name.
The bar we hold
Rigor you can measure.
100%
Licensed-reviewer released
No pack ships without a CPA or EA signature.
5 days
Standard SLA
From complete intake to released pack.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
3
Statutory sources verified
IRC, Treas. Regs., IRS Pubs 1281 & 1586, every applicable file.
Why our engine
Built to be the most thorough option a mid-market AP team has.
Documentation-complete, by design
The deliverable is completeness itself — every statutory clock and action accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide compliance are code, not a model's opinion. A drafting error cannot slip past a statutory deadline.
In its lane, on purpose
We prepare documentation and run searches as your clerical agent. We never contact the payee, give legal advice, or file anything with the IRS on your behalf.
Engagement
Flat fee, per released pack. No contingency, ever.
Simple, predictable, and aligned with a compliance standard — not a cut of any penalty abatement.
- A free CP2100 Exposure Scan before you commit — see exactly what is missing.
- One flat fee per released Compliance Pack; disclosed pass-through mailing costs.
- Optional fixed-fee attorney review for high-exposure or complex cases.
- Optional Penalty-Defense Add-on for 972CG response preparation and reasonable-cause documentation.
FAQ
Questions, answered precisely.
Is your engine a law firm?
No. Our engine, 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 in any legal matter. Licensed reviewer (CPA/EA) review is available and recommended for high-exposure or complex cases.
Do you contact the payee or collect backup withholding?
Never. We are not a debt collector and do not contact payees or debtors. The payer remains the party responsible for sending all notices and remitting backup withholding.
What makes a pack 'complete'?
Completeness is defined by the IRC: the 15-day B-Notice clock verified, backup-withholding trigger computed, first and second B-Notice content compliant, W-9 solicitation tracked, Form 945 draft prepared, and 972CG defense documentation assembled. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a licensed-reviewer 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 mailing costs. No contingency and no percentage of any penalty abatement or recovered amount.
See what's missing before the IRS clock runs out.
Start with a free CP2100 Exposure Scan. Send your IRS notice file and payee master and we'll return a compliance read against every clock and requirement under IRC §§6721, 6722, and 3406.
Documentation-completeness service · not legal advice · the payer sends every notice.