When the adviser disappears

1Summary

A research credit claim and the adviser who prepared it can have very different lifespans. The IRS generally has three years after a return is filed to assess additional tax, and it may ask for more information on a research credit refund claim if the claim is selected for examination.12 Advisory firms close, merge and dissolve. The IRS itself advises taxpayers to "Choose a tax return preparer you'll be able to contact in case the IRS examines your return".3

This paper finds that the consequences of a reduced claim fall on the taxpayer, who repays the credit with interest and may owe a penalty, and who remains "ultimately accountable for the accuracy of every item reported".345 It finds that the duty to keep records falls on the taxpayer, and that the federal rule requiring an adviser to return client records applies only to practitioners.67 It finds that no federal rule requires a research credit adviser to carry professional indemnity insurance, and that recovering money from a firm that has dissolved depends on state corporate law and, in some cases, bankruptcy law.8910

The paper also considers the fee structure. Where a success fee falls due when the credit is received, it will normally have been paid before any examination begins. A promise to refund it if the claim fails is itself a contingent fee under Treasury's rule,11 although under the 2014 Ridgely v. Lew decision the IRS cannot apply that rule to ordinary refund claims filed before an audit.12 The paper describes the law in general terms and is not advice on any particular situation. Swanson Reed's position is stated once, in a labeled box.

2Why the question arises

2.1Claims outlive engagements

A research credit engagement usually ends when the claim is filed or the refund is paid. The claim's legal life continues. Except as otherwise provided, tax must be assessed within three years after the return was filed.1 For refund claims, the IRS says it will try to make determinations within six months of receipt, and information it waived at filing, such as the names of the people who performed each research activity, "may be requested if a refund claim involving the Research Credit is selected for examination".2 An examination can therefore begin well after the adviser's work has ended and its fee has been paid.

2.2What the IRS tells taxpayers

The IRS's guidance on choosing a preparer is direct. It tells taxpayers to choose a preparer they will be able to contact if the IRS examines the return, and states: "Although the tax return preparer always signs the return, you're ultimately accountable for the accuracy of every item reported on your return."3 The same guidance tells taxpayers to avoid preparers "who base their fees on a percentage of the refund".3

2.3No data on adviser failure

No official source found for this paper records how often research credit advisers close, how many claims are examined after the preparer has ceased trading, or what taxpayers recover in those cases. This paper therefore describes the law and its gaps, not their frequency. It does not describe any firm.

3Who carries the liability

3.1The tax, interest and penalties

If a research credit is reduced on examination, the taxpayer repays the credit it should not have received, or loses the refund it claimed. Interest runs on unpaid tax from the last date prescribed for payment, which is the original due date of the return without regard to extensions.513 Where a refund was paid and is later reversed, interest can instead run from the date of the refund, depending on how the refund was paid and recovered.1314

Two penalties can apply. If a claim for refund or credit is made for an excessive amount, "the person making such claim shall be liable for a penalty in an amount equal to 20 percent of the excessive amount", unless the excess is due to reasonable cause.4 The person making the claim is the taxpayer. An accuracy-related penalty of 20 percent can also apply to the portion of an underpayment attributable to negligence or a substantial understatement of income tax.15

None of these liabilities depends on whether the adviser still exists. They attach to the taxpayer because the taxpayer filed the return or claim.

3.2Reasonable cause and reliance on an adviser

A taxpayer can avoid the accuracy-related penalty by showing reasonable cause and good faith, and reliance on professional advice can establish it if, "under all the circumstances, such reliance was reasonable and the taxpayer acted in good faith".16 The regulations set minimum requirements. The advice must be based on all pertinent facts and circumstances, and the requirements are not met "if the taxpayer fails to disclose a fact that it knows, or reasonably should know, to be relevant".16 Reliance may not be reasonable "if the taxpayer knew, or reasonably should have known, that the advisor lacked knowledge in the relevant aspects of Federal tax law".16

These rules are fact-specific, and the taxpayer bears the burden of showing them. A taxpayer whose adviser has closed may find it harder to show what facts it disclosed and what advice it received, if the adviser held the working papers. That is a practical point about evidence, not a rule of law, and this paper does not suggest how any particular case would be decided.

3.3The adviser's own penalties do not compensate the taxpayer

The preparer penalty for an understatement due to an unreasonable position is the greater of $1,000 or 50 percent of the preparer's income from the return or claim.17 It is paid to the government. The government can also ask a court to enjoin a preparer who has engaged in conduct subject to that penalty, or who has "guaranteed the payment of any tax refund or the allowance of any tax credit".18 An injunction stops future conduct. Neither measure returns any money to the taxpayer.

The IRS accepts complaints about preparers on Form 14157.19 Its separate affidavit process for correcting an account after preparer misconduct is for individual filers, and business accounts are not eligible.19 For reports about excess fees paid to a preparer, the IRS says the Treasury Inspector General for Tax Administration has jurisdiction.19

4The records problem

4.1The duty to keep records is the taxpayer's

Every person liable for tax must keep the records the Secretary prescribes.20 For the research credit, the regulations require the taxpayer to "retain records in sufficiently usable form and detail to substantiate that the expenditures claimed are eligible for the credit".6 Form 6765 asks that the name or identifier for each business component in Section G be "consistent with how you maintain the books and records that substantiate the qualified research activities and associated QREs".21

Where the adviser does the analysis that links payroll records to business components and research activities, and keeps that analysis and then closes, the taxpayer may hold the underlying payroll and project records but not the work that connects them to the claim. The IRS told its examiners in 2008 that research credit studies typically involve compiling accounting records, interviewing employees and preparing computational workpapers.22

4.2Circular 230's duty to return records

Circular 230 requires a practitioner, at the request of a client, to "promptly return any and all records of the client that are necessary for the client to comply with his or her Federal tax obligations".7 The definition of client records includes documents the client provided and returns or claims the practitioner prepared for a prior representation where they are needed for current obligations.7 It does not include a return, claim or other document the practitioner prepared "if the practitioner is withholding such document pending the client's performance of its contractual obligation to pay fees with respect to such document".7 Where state law allows a practitioner to retain records in a fee dispute, the practitioner need only return records that must be attached to the return, but must give reasonable access to the rest.7

The rule has two limits. It applies only to practitioners, a term Circular 230 defines by reference to attorneys, certified public accountants, enrolled agents and certain others.8 And it depends on there being a practitioner to ask. A firm that has dissolved cannot be asked.

5What a claimant can recover

5.1The fee

Whether any part of an adviser's fee is refundable when a claim is reduced depends on the engagement letter. No federal rule requires a refund.

For practitioners, Treasury's rule restricts the most direct form of protection. Circular 230 defines a contingent fee to include "any fee arrangement in which the practitioner will reimburse the client for all or a portion of the client's fee in the event that a position taken on a tax return or other filing is challenged by the Internal Revenue Service or is not sustained".11 A practitioner may not charge a contingent fee for preparing a return or refund claim, except where the claim is filed within 120 days of written notice of an examination or challenge, or in the other listed cases.11 A promise to refund the fee if the IRS reduces the claim is therefore restricted in the same way as a success fee, and for the same reason: it gives the adviser a financial stake in whether the claim is challenged. Under the 2014 Ridgely v. Lew decision, however, the IRS cannot apply this rule to ordinary refund claims filed before an audit.12

Where a refund promise is given, its value depends on the adviser's ability to pay when the claim is examined. A promise from a firm that has closed is a claim against that firm.

The employee retention credit shows how far a fee can be beyond recovery. The IRS set the repayment rate in its 2023 voluntary disclosure program at 80 percent because "many of the ERC promoters charged a percentage fee" collected at the time of payment or in advance, "and the recipients never received the full amount".23 Participants were required to identify the advisers who had helped them.23 That was a different credit, and nothing in it is evidence about research credit advisers. It shows that the IRS has recognized that taxpayers may be unable to recover fees already paid.

5.2A claim against the firm

This paper does not survey the contract and state law that would govern any claim by a business against its adviser for a defective research credit claim, and nothing here is advice on whether any such claim exists.

Where the firm has been dissolved, state corporate law sets the window. Under Delaware law, for example, a dissolved corporation continues as a body corporate for three years "for the purpose of prosecuting and defending suits", and an action begun within that period does not abate because of the dissolution.9 A stockholder of a dissolved Delaware corporation whose assets were distributed is generally not liable for a claim beyond the lesser of its pro rata share of the claim and the amount distributed to it, and in some cases not at all if no action was begun within that period.9 Other states have their own rules. Delaware is cited only as an example.

If the firm is in bankruptcy, the filing of a petition operates as a stay of "the commencement or continuation" of actions against the debtor to recover claims that arose before the case began.10 A taxpayer with a claim against the firm would then pursue it in the bankruptcy.

5.3Professional indemnity insurance

Professional indemnity insurance can stand behind a claim against an adviser who is unable to pay, depending on the policy terms. Federal law does not require it. Circular 230 contains no requirement for practitioners to hold professional indemnity insurance, and the federal definition of a tax return preparer imposes none.824 This paper does not survey state licensing rules or professional body requirements in the United States.

The United Kingdom takes a different approach. It is described here factually, not as a recommendation for that country.

United Kingdom. HMRC's 2024 consultation on the tax advice market recorded that some tax practitioners "do not have to hold professional indemnity insurance", noted that "all professional bodies require members to hold professional indemnity insurance", and stated that in 2021 the government had decided not to proceed with mandatory insurance for all advisers because, on its own, it would not be an effective way to raise standards or improve redress.25 In a different market, the FCA requires claims management firms that handle personal injury claims to have professional indemnity insurance.26

Insurance has limits even where it is held, because a policy responds only according to its terms. Where an insured firm has become insolvent, a claimant may need a route to the insurer. In the United Kingdom, the Third Parties (Rights against Insurers) Act 2010 provides such a route. A UK company that has been dissolved can also be restored to the register by court order on the application of a creditor or a person with a potential legal claim, generally within six years of dissolution, and is then "deemed to have continued existing as if it had not been struck off and dissolved".27

5.4A different allocation: Canada's SR&ED penalty

Canada's SR&ED program shows another way to allocate responsibility, for one specific failure. Each claim must disclose the claim preparer and the billing arrangement, including any contingency fee.28 If that information is false or omitted, the claimant is "jointly and severally, or solidarily, liable, together with any claim preparer of the form, to a penalty equal to C$1,000", unless the preparer shows due diligence.29 The penalty is small and concerns disclosure rather than the substance of the claim. It is noted here because it attaches liability to the preparer alongside the claimant.

6Figure 1: what a claimant can and cannot recover

Source of recovery	Federal rule	Limits
Refund of the adviser's fee	None; depends on the engagement letter	A refund-if-challenged promise is a contingent fee under Circular 230, though under Ridgely v. Lew (2014) the IRS cannot apply that rule to ordinary refund claims filed before an audit; worth only what the firm can pay
Damages from the adviser	State law and contract	Not surveyed here; depends on the facts
Claim against a dissolved firm	State corporate law (for example, Delaware: 3 years)	Limited to assets and distributions; time limits
Claim against a bankrupt firm	Federal bankruptcy law	Automatic stay; claim pursued in the bankruptcy
Professional indemnity insurance	None required federally	Policy terms; not all advisers insured
Preparer penalty and injunction	26 U.S.C. 6694 and 7407	Paid to or ordered by the government; no compensation to the taxpayer
Return of records	Circular 230, 31 CFR 10.28	Practitioners only; fee dispute exceptions

Sources: as cited in the text.7119108171812 The table simplifies the rules and is not advice on any particular situation.

7How the fee structure affects the outcome

A fixed-fee adviser can close too, and a business that paid a fixed fee faces the same tax, interest and penalties if its claim is reduced. Nothing in this paper suggests that advisers who charge success fees are more likely to close than others; no data addresses that.

In Swanson Reed's view, the fee structure does affect two things. The first is the size and timing of the payment. A success fee is calculated on the credit. Where a success fee falls due when the credit is received, it will normally have been paid before any examination begins. As an illustration only, on a credit of $200,000 a fee of 20 percent is $40,000, paid at the point the benefit arrives, while the risk of that benefit being reduced continues for years. The second is the incentive at the time the claim is prepared. A fee that rises with the credit rewards each judgment that enlarges the claim, while the consequences of a judgment that does not hold arrive later and fall on the taxpayer.45 Treasury has described that incentive in its own rules.11

The only version of a success fee that would carry part of the examination risk is one that is refunded if the claim fails. That is the arrangement Treasury's rule restricts as a contingent fee,11 although under the 2014 Ridgely v. Lew decision the IRS cannot apply that rule to ordinary refund claims filed before an audit.12 So the fee structure that ties an adviser's income to the size of the claim offers, by design, little that the taxpayer can recover when the claim is examined.

8Steps the record points to

The rules described above suggest some general steps for any business that uses an adviser for a research credit claim, whatever the fee. They are general information, not advice.

Hold the analysis, not only the claim. The taxpayer must keep records that substantiate the credit.6 Obtaining the adviser's working papers, interview notes and the mapping of wages to business components at the end of the engagement means they remain available if the adviser does not.
Know who will support an examination. The engagement letter can say whether examination support is included, how it is priced and what happens if the adviser ceases to trade.
Know whether the adviser is a practitioner. Circular 230's rules on fees and on returning records apply to practitioners.7118
Ask about insurance. No federal rule requires it, so whether the adviser holds it, and on what terms, is a question to ask.8
Keep records for the assessment period. The general period for assessment is three years after the return is filed.1

See our disclaimer.

Our position

Congress should prohibit contingent fees, commonly called success fees, in federal research and development tax credit engagements under Section 41, so that advisers are paid for the work they perform rather than for the size of the claim they produce. Swanson Reed, which publishes this paper, is a fixed-fee R&D tax adviser. It has a direct commercial interest in the outcome: SR Tax Services LLC does not charge success fees, and a ban would remove a pricing model it competes against.

9What the record does and does not show

The record shows that the financial consequences of a reduced claim fall on the taxpayer whether or not the adviser still exists, that the duty to keep records is the taxpayer's, that federal law requires no insurance of research credit advisers, and that a promise to refund a fee if a claim fails is restricted as a contingent fee, although under the 2014 Ridgely v. Lew decision the IRS cannot apply that rule to ordinary refund claims filed before an audit.45611812

It does not show how often research credit advisers close, how many claims are examined after their preparer has gone, or what taxpayers recover. No official source collects that information. The argument in this paper rests on the structure of the law, not on measured outcomes.

References

Office of the Law Revision Counsel, 26 U.S.C. 6501, Limitations on assessment and collection, subsection (a), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap66-subchapA-sec6501.htm (accessed 11 October 2026). Back
Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, questions 5 and 21 (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026). Back
Internal Revenue Service, Topic no. 254, How to choose a tax return preparer (page last reviewed or updated 7 October 2026). https://www.irs.gov/taxtopics/tc254 (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6676, Erroneous claim for refund or credit, subsections (a) and (b), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapB-partI-sec6676.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6601, Interest on underpayment, nonpayment, or extensions of time for payment, of tax, subsection (a), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap67-subchapA-sec6601.htm (accessed 11 October 2026). Back
Treasury Department, 26 CFR 1.41-4, Qualified research for expenditures paid or incurred in taxable years ending on or after December 31, 2003, paragraph (d). https://www.ecfr.gov/current/title-26/section-1.41-4 (accessed 11 October 2026). Back
Treasury Department, Circular No. 230, 31 CFR 10.28, Return of client's records, paragraphs (a) and (b). https://www.ecfr.gov/current/title-31/subtitle-A/part-10/subpart-B/section-10.28 (accessed 11 October 2026). Back
Treasury Department, Circular No. 230, 31 CFR part 10 (full text searched for insurance requirements on 11 October 2026; none found), sections 10.2(a)(5) and 10.3. https://www.ecfr.gov/current/title-31/subtitle-A/part-10 (accessed 11 October 2026). Back
State of Delaware, Delaware Code, Title 8, Chapter 1, Subchapter X, sections 278 and 282. https://delcode.delaware.gov/title8/c001/sc10/index.html (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 11 U.S.C. 362, Automatic stay, subsection (a)(1), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title11/html/USCODE-2024-title11-chap3-subchapIV-sec362.htm (accessed 11 October 2026). Back
Treasury Department, Circular No. 230, 31 CFR 10.27, Fees, paragraphs (b) and (c). https://www.ecfr.gov/current/title-31/subtitle-A/part-10/subpart-B/section-10.27 (accessed 11 October 2026). Back
US District Court for the District of Columbia, Ridgely v. Lew, Civil Action No. 1:12-cv-00565 (CRC), Memorandum Opinion, 16 July 2014, pages 1, 13 and 14 to 15. https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_12-cv-00565/pdf/USCOURTS-dcd-1_12-cv-00565-1.pdf (accessed 11 October 2026). Back
Internal Revenue Service, Internal Revenue Manual 20.2.5, Interest on Underpayments (Manual Transmittal 8 July 2025), sections 20.2.5.7 and 20.2.5.7.1. https://www.irs.gov/irm/part20/irm_20-002-005r (accessed 17 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6602, Interest on erroneous refund recoverable by suit, United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap67-subchapA-sec6602.htm (accessed 17 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6662, Imposition of accuracy-related penalty on underpayments, subsections (a) and (b)(1) and (2), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapA-partII-sec6662.htm (accessed 11 October 2026). Back
Treasury Department, 26 CFR 1.6664-4, Reasonable cause and good faith exception to section 6662 penalties, paragraphs (b)(1) and (c)(1). https://www.ecfr.gov/current/title-26/section-1.6664-4 (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6694, Understatement of taxpayer's liability by tax return preparer, subsection (a), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapB-partI-sec6694.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 7407, Action to enjoin tax return preparers, subsections (a) and (b), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap76-subchapA-sec7407.htm (accessed 11 October 2026). Back
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Cite this paper

Summary

1Summary

2Why the question arises

2.1Claims outlive engagements

2.2What the IRS tells taxpayers

2.3No data on adviser failure

3Who carries the liability

3.1The tax, interest and penalties

3.2Reasonable cause and reliance on an adviser

3.3The adviser's own penalties do not compensate the taxpayer

4The records problem

4.1The duty to keep records is the taxpayer's

4.2Circular 230's duty to return records

5What a claimant can recover

5.1The fee

5.2A claim against the firm

5.3Professional indemnity insurance

5.4A different allocation: Canada's SR&ED penalty

6Figure 1: what a claimant can and cannot recover

7How the fee structure affects the outcome

8Steps the record points to

9What the record does and does not show

References

About this paper

Cite this paper

Summary

1Summary

2Why the question arises

2.1Claims outlive engagements

2.2What the IRS tells taxpayers

2.3No data on adviser failure

3Who carries the liability

3.1The tax, interest and penalties

3.2Reasonable cause and reliance on an adviser

3.3The adviser's own penalties do not compensate the taxpayer

4The records problem

4.1The duty to keep records is the taxpayer's

4.2Circular 230's duty to return records

5What a claimant can recover

5.1The fee

5.2A claim against the firm

5.3Professional indemnity insurance

5.4A different allocation: Canada's SR&ED penalty

6Figure 1: what a claimant can and cannot recover

7How the fee structure affects the outcome

8Steps the record points to

9What the record does and does not show

References

About this paper

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