How long do I have to respond to IRS Letter 106C?

Generally 2 years to sue on the disallowed amount. Use the deadline printed on your notice and verify how it is calculated. IRS deadlines may run from the notice or mailing date and are not automatically extended because the letter arrived or was opened late.

What should I do if I received IRS Letter 106C?

Claim partially disallowed. Reconcile the allowed and denied amounts and protect refund suit rights. If you are unsure, have a tax professional review the letter before you respond to the IRS.

IRS Letter 106C: Claim Partially Disallowed

The IRS allowed part of your refund or credit claim and disallowed the rest. Review the split and protect rights on the denied amount.

Editorially reviewed by the Law Offices of Darrin T. Mish, P.A.Updated October 1, 2026

Notice: Letter 106C
Urgency: Urgent
Deadline: Generally 2 years to sue on the disallowed amount

Your first move

Claim partially disallowed. Reconcile the allowed and denied amounts and protect refund suit rights.

Letter 106C partially disallows a claim for refund or credit. The IRS accepted some of the claim and denied the remainder. The letter should identify the allowed amount, the disallowed amount, and the reason for the partial denial.

Same Rights, Same Deadlines

Reconcile the figures with the claim you filed. If you disagree with the denied portion, follow the letter's instructions for Appeals and protect any refund-suit deadline. A statutory claim-disallowance notice generally starts a two-year period to sue, but confirm the exact legal-rights language on your copy.

Don't Let Deadlines Pass

The 2-year refund suit deadline does not pause while Appeals reviews the claim. Only a written agreement with the IRS on Form 907 extends it. If you miss it, you lose the right to sue for that refund. Even if you plan to pursue Appeals first, keep the 2-year date on your calendar as a backstop.

If you received an LTR 106C, call us at (813) 229-7100. We evaluate claim disallowances and advise on the best path forward.

This letter has a clock on it. Don’t run it out alone.

Free consultation with Darrin T. Mish, a Tampa tax attorney licensed since 1993 and admitted to the U.S. Tax Court. Bring the letter.

Call (813) 229-7100

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