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Morkel Financial & Tax Services

IRS Holding My Refund for Review: Nothing to Do for 60 Days.

By Ewan Morkel, EA6 min read

A CP05 means the IRS is verifying what you reported before it pays you. The notice asks you for nothing, and once the refund passes 45 days after April 15 the delay starts paying you 7%.

Hands opening a brown envelope with a white sheet of paper over a wooden table

A hospital tech e-files a 2025 return on March 2, sees a $7,400 refund at the bottom of it, and spends it on paper. Five weeks in, Where's My Refund stops saying anything useful. In early April an envelope shows up: the IRS is holding the refund while it verifies the return, it needs 60 days, and it asks for nothing. That is a CP05. It is now October and the money still has not moved.

What it is

A CP05 is a verification hold, not an audit.

The notice comes out of Return Integrity Verification Operations, the unit that matches returns against third-party records before refunds go out. It checks whether the wages you reported match what your employer reported, whether the withholding you claimed was actually withheld, and whether the credits hold up. Letter 4464C and Letter 2645C are the same review wearing different numbers, and all three ask for the same 60 days.

It happens more than people assume. The National Taxpayer Advocate's 2025 report to Congress counted more than 30 million individual returns suspended somewhere in processing in fiscal 2025, and about 3.6 million taxpayers paid late, waiting an average of 7 weeks past normal processing after e-filing and 14 weeks on paper. Being flagged is a filter result, not an accusation: in the data the Advocate studied for 2018, the identity theft filters picked legitimate returns 63% of the time.

That makes it a different animal from the two notices people confuse it with. A CP2000 proposes a change to your return and invites you to argue with it. A CP14 bills you for tax you already reported and did not pay. A CP05 does neither: no balance due, no deadline on your side, nothing to sign.

The 60 days

IRS holding my refund for review: what the 60 days are for.

The 60 days run from the notice date, not from the day you filed. The notice tells you not to call before they are up, and that is not a brush-off: the assistor who answers can see the hold and cannot release it, so a call on day 20 buys you a sentence you already have in writing.

Two things are worth doing while you wait. Pull your wage and income transcript in your IRS Online Account and compare it to your return, because the most common honest cause of a verification hold is a W-2 the employer filed late, filed wrong, or never filed. Then confirm your withholding matches box 2 of every W-2 and the withholding box on every 1099, since a transposed figure there is what the filter is built to catch.

Two things are worth not doing. Do not file the return a second time, which creates a duplicate and buries the original in a slower queue. And do not amend while the hold is open, because an amended return starts a separate, slower process that was still backed up above normal at the end of 2025.

The interest

Past day 45, the wait starts paying 7%.

This is the part nobody mentions. §6611(a) allows interest on an overpayment, and §6611(e)(1) carves out a processing window: no interest at all if the refund is paid within 45 days after the later of the unextended due date or the date you filed. For a 2025 return filed by April 15, 2026, that window closed May 30, 2026. Past it, interest runs, and it runs from April 15 rather than from day 46, because §6513(b)(1) deems tax withheld from wages to have been paid on the due date.

The rate is the federal short-term rate plus 3 points for individuals, which the IRS held at 7% for the quarter beginning October 1, 2026 in Rev. Rul. 2026-15. Two caveats. §6611(b)(2) lets the IRS run the clock only to a date up to 30 days before it cuts the refund, so the figure lands short of a straight day count. And the interest is taxable in the year you receive it, reported on a Form 1099-INT if it comes to $10 or more.

A $7,400 refund on a 2025 return, e-filed March 2, 2026 and paid September 18, 2026.
Refund claimed on the return
$7,400
Last day the IRS can pay it with no interest, 45 days after April 15
May 30, 2026
Interest if the refund arrives on or before that date
$0
Days from April 15, 2026 to the September 18 payment
156
Interest at 7% compounded daily over those 156 days
$225
Interest if the IRS stops the clock the full 30 days early under §6611(b)(2)
$181
Federal tax on the interest on the 2026 return, 22% bracket
$50
Interest kept after tax
$175
What $7,400 would have earned in a 4% savings account over the same 156 days
$127

Tax year 2025 federal return, single filer, refund entirely from wage withholding, no state tax. Withholding is deemed paid on April 15, 2026 under IRC §6513(b)(1), which is the date overpayment interest runs from under §6611(d). §6611(e)(1) allows no interest at all if the refund is issued within 45 days after the later of the unextended due date or the filing date, which is May 30, 2026 on these facts. Interest is figured at the 7% overpayment rate for individuals in Rev. Rul. 2026-15, compounded daily, fixed through December 31, 2026 and reset quarterly after that. §6611(b)(2) lets the IRS run interest only to a date up to 30 days before the refund, which is the $181 line. Interest the IRS pays is taxable in the year received, and the $50 assumes a 22% bracket in 2026. The savings account line is simple interest at 4%.

If a CP05A comes

The follow-up notice is the one with a deadline.

Inside the 60 days the IRS does one of three things: releases the refund, sends another interim letter, or sends a CP05A. The CP05A moves the work to you. It lists the items it could not verify and gives 30 days to send documents: pay stubs, a letter from the employer on company letterhead showing dates of employment and withholding, or copies of the checks.

Miss that deadline and the IRS resolves the question against you. Withholding it cannot verify comes off, credits it cannot verify get disallowed, and the refund shrinks by an adjustment notice. That is recoverable, but through the deficiency and claim procedures rather than a 30-day document upload, which costs months. Answer it, send it to the address or fax printed on the notice, and keep proof of what went out and when.

Day 61

What actually moves a stuck refund.

Start with the number on the notice, with a copy of the return in front of you. If the 60 days have passed and nothing has happened, you also have standing with the Taxpayer Advocate Service. §7811(a)(2) defines significant hardship to include a delay of more than 30 days in resolving a taxpayer account problem, which a blown 60-day review is. The request is Form 911.

Be realistic about what that buys. TAS cannot override a mandatory review or hand you the refund early. What it can do is make sure the case is being worked instead of sitting, which on a file that has gone quiet is most of the problem. The hard ceiling is the PATH Act: §6402(m) bars any refund on a return claiming the earned income credit or the additional child tax credit before February 15, and nobody lifts that one, hardship or not.

One version of this is not a waiting problem. If the CP05 is for a return you did not file, it is identity theft, and the move is Form 14039 plus a call to the number on the notice. The Advocate reported identity theft victims waiting an average of more than 21 months for the IRS to resolve their cases, and that clock starts when you report it.

Frequently asked

Quick answers on this topic.

Does a CP05 notice mean I am being audited?

No. A CP05 is a pre-refund verification hold out of Return Integrity Verification Operations, not an examination. It proposes no change to your return, assesses nothing, and carries no appeal rights, because nothing has been determined yet. An audit opens with a different letter that asks for records by a date. A CP05 asks for nothing, and it only turns into an examination if a CP05A response fails to verify what you reported.

Will the IRS actually pay me the interest, or do I have to ask for it?

It computes the interest itself and adds it to the refund, usually in the same deposit, so there is nothing to apply for. The rate is 7% compounded daily for the quarter beginning October 1, 2026 under Rev. Rul. 2026-15, and it runs from April 15 on a refund made up of wage withholding. If the refund lands with no interest on it and it was clearly more than 45 days past April 15, call the number on the notice and ask.

Can my tax preparer get the hold released faster?

Not released, but a preparer holding a Form 2848 can call the Practitioner Priority Service and read your account, which tells you which hold is on it, whether a CP05A is queued, and whether the IRS is waiting on something from you. Nobody releases a verification hold by phone, including the Taxpayer Advocate Service. What representation buys here is knowing what is actually happening instead of guessing.

I need the money now. Does financial hardship get my refund released?

Sometimes. IRC §7811(a)(2) lets the Taxpayer Advocate Service act on economic harm, an immediate threat of adverse action, significant costs, or irreparable injury, and a request on Form 911 documenting rent, utilities, or medical bills is how you raise it. Expedited handling is discretionary rather than automatic. The one absolute wall is §6402(m), which bars any refund on a return claiming the earned income credit or the additional child tax credit before February 15, hardship or not.

The 60 days passed, I called, and they told me to wait another 60. Is that allowed?

There is no statute capping how long a pre-refund review can run, so a second 60-day letter is not a violation, and Letter 2645C is often what it arrives as. It does mean you now meet the §7811(a)(2) criterion of a delay of more than 30 days in resolving an account problem, which is the point to file Form 911 rather than wait again. Interest keeps accruing at 7% the whole time.

Wage and withholding planning

Squaring the withholding before the return is due.

Two W-2 jobs, a midyear job change, or a working spouse stack income in ways no single W-4 sees, which is how an over-withheld Social Security credit ends up sitting next to an underpayment penalty. We reconcile the wages, claim the excess Social Security credit, and reset the withholding, so the surprise lands in the plan instead of on the return.

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