Kwong: Actions You Need to Take Now
Practical Approach for Time Sensitive Protective Refund Claims - Recorded 6/3/26
In Kwong v. United States (Fed. Cl. 2025), the court read §7508A(d) to create a mandatory postponement running January 20, 2020 through July 10, 2023. Penalties and interest assessed on returns and payments due inside that window may have accrued improperly - but relief isn't automatic, the IRS hasn't acquiesced, and most claims must be filed by July 10, 2026. This session gives practitioners a practical framework to identify the years at issue and triage which claims justify a protective claim now.
Learning Objectives