irs erroneous refund
The IRS erroneous refund revival theory would allow the IRS to administratively collect all $2,000 of the erroneous refund to Alex, $4,000 of the $7,000 erroneous refund to Blair, and $4,000 from Cody (the $2,000 erroneous refund and the $2,000 unpaid on the original assessment).