
Kwong v. United States Penalty Abatement: How to File a Form 843 Claim Before July 10, 2026
The Court of Federal Claims held in Kwong v. United States that IRC §7508A(d) automatically postponed every federal tax deadline from January 20, 2020 through July 10, 2023. The IRS has appealed, but the refund window for COVID-era failure-to-file penalties, failure-to-pay penalties, estimated tax penalties, and underpayment interest closes on July 10, 2026. Here is how the ruling works and how to file a protective Form 843.
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