Federal · Internal Revenue Service

Refund claim disallowed

Letter 105C · Letter 106C

What it is: A claim for refund (an amended return, a Form 843, or a credit claim) was disallowed in full (105C) or in part (106C). The letter is the formal notice of disallowance, and it starts the two-year clock on a refund suit.
The clock it starts: Two years from the mailing date of the disallowance to file a refund suit. An Appeals review can be requested within the period the letter states, generally 30 days; a Form 2297 waiver or a Form 907 extension changes the two-year period only if signed.
What a response has to establish: A request for Appeals review that states why the claim is timely under §6511 and correct on the merits, and preserves the suit date.
Authority: IRC §6532
IRC §7422
IRC §6511
Form 12203
IRS Publication 5

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An Appeals request on the disallowed claim with the limitations analysis and the merits, written to be filed as the protest.

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