IRS NOTICE REFERENCE
Letter 106 C
The “Claim Partially Disallowed” IRS Letter 106C is your legal notice the IRS is not fully allowing the credit or refund you claimed.
General information only. Not legal or tax advice.
Notice details
- Notice code
- Letter 106-C
- Category
- Refund claims and litigation
- Severity tier
- Tier 4 — Escalation warranted. The notice involves collection enforcement, appeals rights, or significant penalty exposure.
- Governing law
- §6532; §7422; §6511 (Internal Revenue Code sections)
- Escalation flag
- This notice carries a forfeitable right, a hard statutory deadline, or criminal-preparer risk. It is flagged for escalation in the TaxRiskOS workflow.
- Source
- IRS Taxpayer Advocate Service
What this notice is
The “Claim Partially Disallowed” IRS Letter 106C is your legal notice the IRS is not fully allowing the credit or refund you claimed.
Source: IRS Taxpayer Advocate Service. Reproduced for reference. General information — not legal or tax advice.
What the IRS says to do
If you agree with the IRS for the reasons stated in the letter, you don’t need to do anything further. If you do not agree, and still believe you are entitled to the credit or refund, you should send an explanation of why you believe you are entitled to the credit or refund along with documentation proving your position. It is important in your correspondence with the IRS that you indicate if the IRS does not agree you are entitled to the additional refund, that they forward your request to the IRS Independent Office of Appeals (Appeals), which will decide if the claim should be allowed. You can at any time, file suit with the United States District Court that has jurisdiction or with the Un
This is the IRS’s own guidance reproduced from the IRS notice page. It describes the IRS’s process — it is not legal or tax advice from TaxRiskOS.
Governing IRS procedure (Internal Revenue Manual)
The IRS’s own internal procedures for handling this notice type are documented in the Internal Revenue Manual:
- IRM 4.10.11 — 4.10.11 Claims for Refund, Requests for Abatement, and Audit Reconsiderations
- IRM 4.19.16 — 4.19.16 Claims
Reference to published IRS procedure. General information — not legal or tax advice.
Official IRS reference
Read the official notice page on IRS.gov: https://www.taxpayeradvocate.irs.gov/notices/letter-106-c/
Related tools
TaxRiskOS is workflow software for practitioners — it captures the notice, computes the deadline, surfaces the escalation tier, and builds a document checklist. It documents process; it does not give advice or draft responses.
Check this notice’s deadline (free tool)