A recent federal court decision, Kwong v. United States, has created a potential refund and abatement opportunity for taxpayers who were assessed IRS penalties or interest on federal tax obligations during the COVID-19 federal disaster period (January 20, 2020 through July 10, 2023). The decision remains unsettled, as the government has appealed, but many affected taxpayers cannot wait for the outcome: a formal refund claim or protective refund claim may need to be filed by July 10, 2026 to preserve their rights.








