I have a tax client who applied for the ERTC for tax years 2020 and 2021 and received $60k of refunds from the IRS in 2024 and paid out $17k to the company that processed them for him.   I know the 60k should be applied against payroll in an amended return for 2020 and 2021, but in what year does the $17k get expensed?   In 2024, the year it was paid, or netted against the refunds on the amended returns?   My client shut down his business in 2024 and didn't have much income so it is more beneficial taxwise to be able to net the fee against the refunds in those amended returns when his income was much higher.