mine took 6 months to unfreeze last year. hang in there!

I feel your pain! I had a similar situation with my 2021 return - code 810 freeze that lasted forever. The zero AGI showing on your transcript is definitely a red flag that might be triggering additional reviews. Have you checked if all your W-2s and 1099s were properly reported? Sometimes mismatched income info can cause these extended freezes. Also try calling the practitioner priority line early morning (7am) - I had better luck getting through that way. Keep us posted on any updates!

This is such helpful information! I'm in a similar situation with a Japanese client and have been putting off dealing with the Form 8802 because it seemed so complicated. Reading through everyone's experiences makes it feel much more manageable. One question I have - when you submit Form 8802, do you need to include copies of your previous tax returns or other supporting documents? Or is just the completed form sufficient? I want to make sure I have everything ready before I submit so I don't get delayed like some of you experienced. Also, for those who successfully got their withholding reduced, did your Japanese clients require any advance notice before they could implement the lower rate? I'm wondering if I should give my client a heads up that this certificate is coming.

I went through this exact process last year and wanted to add a few practical tips that really helped me. First, when you're filling out Form 8802, make sure to be very specific in Section 6 about your business activities with Japan. Don't just write "consulting" - describe exactly what services you provide because the IRS needs to determine which treaty article applies to your income. Also, keep detailed records of all your Japanese withholding statements (the documents showing the 10.21% withheld). You'll need these for your U.S. tax return to claim foreign tax credits, and having them organized makes the whole process smoother. One thing that surprised me was that my Japanese client's accounting department needed about 6 weeks to update their systems once I provided the Form 6166 certificate. They had to coordinate with their local tax office and update their payroll system. So even after you get your certificate, there might be a delay before you see the reduced withholding in your payments. Just plan for that timing when you're budgeting your cash flow. The whole process was definitely worth it though - going from 10.21% to 0% withholding made a huge difference in my monthly income!

One more thing - when you respond to the CP2000, don't just send a stack of documents without explanation. Create a simple cover letter that clearly states: 1) You agree/disagree with the notice 2) The exact reason (Robinhood reported proceeds without cost basis) 3) A simple calculation showing your actual gain/loss I made the mistake of just sending in statements without a clear explanation and ended up getting another notice because they couldn't figure out what I was trying to show them.

As someone who just went through this exact same nightmare with Robinhood, I wanted to share what worked for me. I got a CP2000 for $23K that I definitely didn't owe. The key thing that saved me time was organizing everything before I responded. I created a spreadsheet with three columns: what the IRS thought I made, what I actually made, and the difference. Then I attached the supporting Robinhood documents for each transaction. What really helped was calling the number on the CP2000 notice (yes, you'll be on hold forever, but it's worth it). The agent told me that as long as I could prove my cost basis with official brokerage statements, they would accept my response. She also mentioned that these Robinhood cases are super common right now - apparently their reporting system changed and it's causing tons of these notices. My advice: Don't panic, gather ALL your Robinhood tax documents (the complete package, not just the summary), and respond with a clear explanation. It took about 8 weeks, but I got a revised notice showing I owed $0. You've got this!

11 Has anyone used a CPA or tax attorney to deal with this kind of situation? Wondering if it's worth the cost or if I'm better off handling it myself.

I went through a similar situation a few years back - owed about $52k and was terrified of losing my retirement savings. Here's what I learned: You can't really "volunteer" for a levy, but you can definitely be proactive. The IRS would much rather work with you than seize assets. When they do levy retirement accounts, you avoid the 10% penalty but still owe income tax on the distribution. My advice: Call the IRS immediately (or use one of those callback services mentioned here - they actually work). Be honest about your situation and request a reinstatement of your installment agreement. They often approve modified terms, especially if you can make a good faith payment upfront. I ended up making a partial withdrawal from my 401k (took the penalty hit) to show good faith, then negotiated a manageable monthly payment for the rest. Yes, it hurt short-term, but it kept me in control of the situation rather than having them dictate terms. Don't wait for the levy - once collection enforcement starts, you have way fewer options and much less negotiating power.

Has anyone successfully done the "file 1120 now, then amend later when approved" approach? I'm in the same boat but worried about the complexity of amending a C corp return to zero and filing a new S corp return later. Feels like it could create more problems.

I've been through this exact situation multiple times, and here's my recommended approach based on experience: **First, file Form 7004 immediately** to get a 6-month extension for both the 1120 and 1120S returns. This is crucial - you're at the deadline now and need to protect against penalties. **Second, document everything about your Form 2553 submission.** Keep copies of certified mail receipts, fax confirmations, or any proof of timely filing. The IRS is still experiencing major processing delays, so 2 months without response is unfortunately normal. **Third, avoid the "file 1120 then amend" strategy.** I've seen this create unnecessary complexity and potential state tax issues. It's much cleaner to wait for the S election approval and file correctly the first time. While waiting, you might want to prepare both returns so you're ready either way. If the S election is approved, file the 1120S. If denied (rare but possible), you'll have the 1120 ready to go within your extension period. The key is that Form 7004 buying you time - use it. Most S elections that are properly completed do get approved, it just takes time with current IRS processing delays.