A taxpayer can produce thousands of pages and still reach Appeals with a thin file. Here is why missing IRS file custody changes the hazards—and what PAM should do.

Status 12 says an IRS examination started. It does not prove the ERC issues were developed. Letter 105-C cases can reach Appeals—and PAM—with a remarkably thin file.

ERC and research credit disputes are fact-heavy, document-heavy, and often difficult to resolve through position papers alone. PAM can create the focused conversation these cases need.