"The expense to collect that credit is large, and should be used as an expense to receive income in that year as well."

The checks to pay the ERTC consultants are treated just exactly as a check paid in January for goods & services consumed/used in December.   If a 'cash basis' taxpayer, the dates of the checks are the guiding factor.  doesn't matter if it's $1.00 or $100,000.  Logic and fairness have never been the calling cards of the IRS.  I suppose if a client was an accrual basis taxpayer, you might could match them up. Just so happens that all the clients I did (about 30 or so), were all cash basis.

About 1/2 of mine have rec'd their refunds in this calendar year.  I am convinced that now, and the IRS would never admit this, that any claim below a certain threshold gets just an automatic approval and checks disbursed.  Clients are ultra happy to get the 'interest' part of the checks but stunned when they get the interest assessment on the new tax liability caused by smaller wages expenses in those years.