I have the same issue, but my client received $170k in ERC funds in 2022 for 2021 amended 941s.  If we amend his 1120s his personal K-1 will now show $170k in more income which will result in at least $50k in more state and federal taxes that was due in early 2022.  What happens to the failure to pay penalties and interest that will be due along with the taxes owed?  I think we should be able to place the ERC money into the 2022 tax return, this would solve those issues since the ERC money wasn't received until 2022.