The Oklahoma Bar Journal May 2026

When to refer out: Referral is rarely necessary. Identity veri fication is best handled directly by the taxpayer, as they are in the best position to confirm their own identity. In most cases, attorney involvement adds cost without increasing efficiency. 7) Refund Hold/Return Review Letter Number: CP05 Notice Type: Informational What it is: The IRS is holding the return longer to verify income, withholding, credits and/or business income and asks the tax payer to allow up to 60 days before contacting the IRS. Why your client gets it: Returns may be selected for review at random or flagged by IRS verification filters due to mismatches or risk indicators. The IRS specifically notes that selection for review does not mean the taxpayer made an error or acted improperly. How to handle it: If the client filed the return, no action is required. The IRS advises taxpayers not to call until 60 days have passed from the notice date and only if no further cor respondence has been received. If the client did not file the return, the notice may indicate potential identity theft. You may assist the client in com pleting and submitting Form 14039 (Identity Theft Affidavit). When to refer out: Referral is generally unnecessary, as this is a notice-only letter in most cases. 8) Overpayment Applied/Refund Seized Letter Number: CP49, CP92 Notice Type: Informational (responsive if contested) What is it: The IRS sends this letter to notify taxpayers that an overpayment or state tax refund has been applied to offset an existing IRS balance. Why your client gets it: When a taxpayer overpays for a given tax year, that amount is typically refunded. However, if the taxpayer has outstanding balances from prior years, the IRS may apply the over payment – or seize a state tax refund – to reduce those liabilities. How to handle it: If the client owes the balances and is already making payments, no further action is required. If the client was unaware of prior balances, this letter may serve as a prompt to review their account and address unresolved liabilities. Appealing the offset is generally unnecessary unless there is a legitimate dispute regarding the balance owed or the IRS’s authority to apply the refund. When to refer out: If the client wishes to contest the offset, referral is advisable. These disputes can be time-consuming and often require familiarity with IRS account mechanics and internal processing errors.

If the client disagrees, contact the IRS by the deadline shown in the notice and be prepared to provide sup porting documentation. When to refer out: Referral is advisable if the adjustment masks a more substantive issue – such as credit eligibility, dependency claims or documentation gaps – or if the client intends to contest the correction. Disputing a math error often escalates the matter, and submitting a well-supported response at the outset is critical to preserving appeal options. 5) “We Need More Information To Process Your Return” What it is: Letter 12C is issued when the IRS needs additional information to process a filed return. Common requests include missing or corrected forms, verification of income, withholding or credits or confirmation of taxpayer identification information. Why your client gets it: This notice is often triggered by miss ing schedules, missing forms, wage or withholding discrepan cies or documentation mismatches. How to handle it: The IRS generally requires the requested information to be submitted within 20 days of the notice date. The IRS instructs taxpayers not to file a Form 1040-X in response to the letter. Respond even if the taxpayer disagrees with the IRS’s position, providing clear explanations and supporting documentation. When to refer out: These notices can often be handled in-house when the issue is limited to missing or corrected paperwork. Referral is appropriate when the client lacks required documen tation and does not accept that the missing information may result in an additional tax liability. 6) Identity verification Letter Number: CP5071, 5071C, CP5071F Notice Type: Responsive What it is: The IRS issues this notice when a return has been filed using a taxpayer’s SSN or ITIN, and the IRS requires the taxpayer to verify their identity and the authenticity of the return before continuing processing. Why your client gets it: The client did not file the return, indicating potential identity theft. The client did file the return, and the IRS requires iden tity verification before proceeding. How to handle it: Have the client follow the verification instructions included in the letter. Letter Number: Letter 12C Notice Type: Responsive

Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.

MAY 2026 | 23

THE OKLAHOMA BAR JOURNAL