ERC refund suit survives without pleading the specific shutdown order

Region IV Mental Health Services filed administrative ERC claims of $5,381,683.35 on October 24, 2022, covering the first three quarters of 2021. The IRS paid $1,990,593.87 for the second quarter on June 5, 2023, then disallowed all three quarters by letter dated April 17, 2024. Region IV sued. On July 1 the Northern District of Mississippi dismissed the declaratory judgment request under 28 U.S.C. 2201(a) and section 7421(a), but denied dismissal of the refund claims. The court rejected the government's shotgun pleading argument, holding that specificity about the governmental orders was not required at the pleading stage. It also found jurisdiction over the second quarter claim despite the later assessment. No free public URL for the order in No. 3:26-CV-12 was found.