( February 20, 2026, 8:26 AM EST) -- NEW HAVEN, Conn. — A taxpayer seeking to compel the Internal Revenue Service to process its claim of employee retention credits (ERC) it says it is owed under the Coronavirus Aid, Relief, and Economic Security (CARES) Act and apply the credits to its tax liability amended its complaint in response to the government’s motion to dismiss nearly all the counts of the taxpayer’s first amended complaint, including violations of due process and equal protection by the IRS in its efforts to collect payroll taxes without offsetting the anticipated credits....