Fact Sheet – covers an audit – and says if you filed for the tax credit in good faith, you will not be subject to penalties. If the IRS FAQ’s are in error the law will prevail. Lastly – You have protection is you depended on a prior version of facts when you filed for a tax credit.
CARES Act – Disruption of Business Operations – This is where the law lays out disruption of business and would be where the IRS would have to fall back on.