| Ex. GOV-012 | Order on Cross-Motions for Summary Judgment, Doc. 49 (D. Ariz. June 20, 2025), docket originalOrder on Cross-Motions for Summary Judgment, Doc. 49 (D. Ariz. June 20, 2025), docket original | | United StatesLegal authority | June 20, 2025 | | Court filing | Primary source read | |
| Ex. LAW-005 | Pub. L. 119-21, 139 Stat. 72 (July 4, 2025) (sec. 70605 at 286-289)Pub. L. 119-21, 139 Stat. 72 (July 4, 2025) (sec. 70605 at 286-289) | United States Congress | Legal authority | July 4, 2025 | | Legal authority | Primary source read | |
| Ex. GOV-003 | IRS, Frequently asked questions about the Employee Retention Credit, 'Qualifying government orders' Q5/A5 ('What does "more than nominal" mean...') (added Sept. 14, 2023), page as rendered Sept. 26, 2026IRS, Frequently asked questions about the Employee Retention Credit, 'Qualifying government orders' Q5/A5 ('What does "more than nominal"… | | United StatesLegal authority | July 25, 2025 | | Court filing | Primary source read | |
| Ex. LAW-076 | In re JSmith Civil, LLC, No. 24-00004-5-JNC, Doc. 47 (Bankr. E.D.N.C. Aug. 7, 2025), 674 B.R. 207In re JSmith Civil, LLC, No. 24-00004-5-JNC, Doc. 47 (Bankr. E.D.N.C. Aug. 7, 2025), 674 B.R. 207 | United States Bankruptcy Court, E.D.N.C. | Legal authority | Aug. 7, 2025 | | Legal authority | Primary source read | |
| Ex. GOV-010 | Opening Brief for Plaintiff-Appellant, Stenson Tamaddon, LLC v. IRS, No. 25-4217 (9th Cir. Sept. 17, 2025), DktEntry 11.1Opening Brief for Plaintiff-Appellant, Stenson Tamaddon, LLC v. IRS, No. 25-4217 (9th Cir. Sept. 17, 2025), DktEntry 11.1 | | United StatesLegal authority | Sept. 17, 2025 | | Court filing | Primary source read | |
| Ex. LAW-117 | FS-2025-07 (October 22, 2025; updated October 30, 2025): FAQs on Pub. L. 119-21 section 70605, IRS Fact Sheet FS-2025-07 (announced by IR-2025-106)FS-2025-07 (October 22, 2025; updated October 30, 2025): FAQs on Pub. L. 119-21 section 70605, IRS Fact Sheet FS-2025-07 (announced by… | Internal Revenue Service | Legal authority | Oct. 22, 2025 | | Legal authority | Primary source read | |
| Ex. LAW-086 | JPM Restaurant, LLC v. United States, No. 1:24-cv-357, Doc. 49 (E.D. Tenn. Oct. 29, 2025) (order denying reconsideration of stay)JPM Restaurant, LLC v. United States, No. 1:24-cv-357, Doc. 49 (E.D. Tenn. Oct. 29, 2025) (order denying reconsideration of stay) | United States District Court, E.D. Tenn. | Legal authority | Oct. 29, 2025 | | Legal authority | Confirmed from a secondary source | |
| Ex. LAW-079 | Lemus-Escobar v. Bondi, No. 18-73423 (9th Cir. Nov. 10, 2025) (order and amended opinion), reported at 158 F.4th 944 (per Tri-State at 7-8)Lemus-Escobar v. Bondi, No. 18-73423 (9th Cir. Nov. 10, 2025) (order and amended opinion), reported at 158 F.4th 944 (per Tri-State at 7-8) | United States Court of Appeals for the Ninth Circuit | Legal authority | Nov. 10, 2025 | | Legal authority | Primary source read | |
| Ex. LAW-083 | Plastic Film, LLC v. United States, No. 5:25-cv-30-DCB-LGI, Doc. 18 (S.D. Miss. Jan. 20, 2026)Plastic Film, LLC v. United States, No. 5:25-cv-30-DCB-LGI, Doc. 18 (S.D. Miss. Jan. 20, 2026) | United States District Court, S.D. Miss. | Legal authority | Jan. 20, 2026 | | Legal authority | Primary source read | |
| Ex. GOV-011 | Brief for the Appellees, Stenson Tamaddon, LLC v. IRS, No. 25-4217 (9th Cir. Jan. 30, 2026), DktEntry 25.1Brief for the Appellees, Stenson Tamaddon, LLC v. IRS, No. 25-4217 (9th Cir. Jan. 30, 2026), DktEntry 25.1 | | United StatesLegal authority | Jan. 30, 2026 | | Court filing | Primary source read | |
| Ex. LAW-075 | Gravenstein 116, LLC v. United States, No. 25-997 (Fed. Cl. Jan. 30, 2026), 180 Fed. Cl. 292Gravenstein 116, LLC v. United States, No. 25-997 (Fed. Cl. Jan. 30, 2026), 180 Fed. Cl. 292 | United States Court of Federal Claims | Legal authority | Jan. 30, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-118 | GAO-26-107456, 'COVID-19 Relief: IRS Can Use Lessons Learned to Address and Prevent Improper Payments in Future Tax Programs' (February 10, 2026), GAO-26-107456, Highlights page; pp. 27, 30, 49 (PDF pp. 2, 32, 35, 54)GAO-26-107456, 'COVID-19 Relief: IRS Can Use Lessons Learned to Address and Prevent Improper Payments in Future Tax Programs' (February 10… | Internal Revenue Service | Legal authority | Feb. 10, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-153 | GAO-26-107456, 'COVID-19 Relief: IRS Can Use Lessons Learned to Address and Prevent Improper Payments in Future Tax Programs' (February 10, 2026), GAO-26-107456, Highlights page; pp. 27, 30, 49 (PDF pp. 2, 32, 35, 54)GAO-26-107456, 'COVID-19 Relief: IRS Can Use Lessons Learned to Address and Prevent Improper Payments in Future Tax Programs' (February 10… | Internal Revenue Service | Legal authority | Feb. 10, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-139 | Taxpayer Advocate Service FY2026 Objectives Report, Objective 6 (published February 11, 2026; updated May 29, 2026), taxpayeradvocate.irs.gov, Objective 6 status pageTaxpayer Advocate Service FY2026 Objectives Report, Objective 6 (published February 11, 2026; updated May 29, 2026)… | Internal Revenue Service | Legal authority | Feb. 11, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-027 | ERC Today, LLC v. McInelly, No. 25-2642 (9th Cir. Mar. 17, 2026) (memorandum)ERC Today, LLC v. McInelly, No. 25-2642 (9th Cir. Mar. 17, 2026) (memorandum) | United States Court of Appeals for the Ninth Circuit | Legal authority | Mar. 17, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-029 | Juggler Dave and Friends, LLC v. United States, No. 25-338 (Fed. Cl. Mar. 25, 2026)Juggler Dave and Friends, LLC v. United States, No. 25-338 (Fed. Cl. Mar. 25, 2026) | United States Court of Federal Claims | Legal authority | Mar. 25, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-137 | National Taxpayer Advocate blog, April 27, 2026 (updated May 1, 2026): 'Protect Your Employee Retention Credit Claim: Use IRS's New Streamlined Process to Request an Extension', taxpayeradvocate.irs.gov NTA Blog (Wayback capture 20260519230327); IRS 'Understanding your CP320B notice' page (Page Last Reviewed or Updated: 23-Apr-2026)National Taxpayer Advocate blog, April 27, 2026 (updated May 1, 2026): 'Protect Your Employee Retention Credit Claim: Use IRS's New… | Internal Revenue Service | Legal authority | Apr. 27, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-151 | IRS.gov 'If you receive Letter 106-C about the Employee Retention Credit', irs.gov/coronavirus/if-you-receive-letter-106-c-about-the-employee-retention-credit, Page Last Reviewed or Updated: 27-Apr-2026 (saved September 27, 2026 as LAW-151)IRS.gov 'If you receive Letter 106-C about the Employee Retention Credit'… | Internal Revenue Service | Legal authority | Apr. 27, 2026 | | Legal authority | Primary source read | |
| Ex. GOV-002 | Tri-State Memorial Hospital v. United States, No. 2:25-cv-0181-TOR, ECF No. 38 (E.D. Wash. May 28, 2026), Order Denying Defendant's Motion to DismissTri-State Memorial Hospital v. United States, No. 2:25-cv-0181-TOR, ECF No. 38 (E.D. Wash. May 28, 2026), Order Denying Defendant's Motion… | | United StatesLegal authority | May 28, 2026 | | Court filing | Primary source read | |
| Ex. LAW-080 | Northeast Health Services, LLC v. United States, No. 24-2096T (Fed. Cl. May 28, 2026) (for publication)Northeast Health Services, LLC v. United States, No. 24-2096T (Fed. Cl. May 28, 2026) (for publication) | United States Court of Federal Claims | Legal authority | May 28, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-074 | First Source Employee Management, Inc. v. United States, No. 1:24-cv-02209-CEF, Doc. 19 (N.D. Ohio June 11, 2026)First Source Employee Management, Inc. v. United States, No. 1:24-cv-02209-CEF, Doc. 19 (N.D. Ohio June 11, 2026) | United States District Court, N.D. Ohio | Legal authority | June 11, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-084 | Plastic Film, LLC v. United States, No. 5:25-cv-30-DCB-LGI, Doc. 45 (S.D. Miss. June 22, 2026)Plastic Film, LLC v. United States, No. 5:25-cv-30-DCB-LGI, Doc. 45 (S.D. Miss. June 22, 2026) | United States District Court, S.D. Miss. | Legal authority | June 22, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-028 | Sundancer Pools, Inc. v. United States, No. 25-1291T (Fed. Cl. June 23, 2026)Sundancer Pools, Inc. v. United States, No. 25-1291T (Fed. Cl. June 23, 2026) | United States Court of Federal Claims | Legal authority | June 23, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-031 | Tapestry Senior Housing Management, LLC v. United States, No. 25-cv-3419, ECF No. 29 (D. Minn. June 25, 2026)Tapestry Senior Housing Management, LLC v. United States, No. 25-cv-3419, ECF No. 29 (D. Minn. June 25, 2026) | United States District Court, D. Minn. | Legal authority | June 25, 2026 | | Legal authority | Primary source read | |
| Ex. LAW-030 | Key Meetings, Inc. v. United States, No. 3:25-cv-06520-WHO, ECF No. 44 (N.D. Cal. June 26, 2026)Key Meetings, Inc. v. United States, No. 3:25-cv-06520-WHO, ECF No. 44 (N.D. Cal. June 26, 2026) | United States District Court, N.D. Cal. | Legal authority | June 26, 2026 | | Legal authority | Primary source read | |