Gray Proctor and Andy Steigleder will present a free CLE for The Florida Bar entitled “COVID-19 Interest Abatement: Kwong, Abdo, and Section 7508A” on April 1, 2026. The recording will be available on YouTube until October 31, 2027.
The Internal Revenue Code contains several provisions that toll tax-related deadlines for taxpayers. Section 7508 applies to members of our armed forces. While every soldier is deployed on combat duty, section 7508 suspends the deadline to file returns and to pay taxes. The government does not charge interest on taxes that go unpaid during deployment, either. Neighboring section 7508A, by cross-reference to section 7508, creates a mandatory suspension of the same deadlines for taxpayers living in a declared disaster area. When the COVID-19 emergency was declared in January 2020, section 7508A was triggered for taxpayers nationwide. The deadlines remained suspended until after the state of emergency was lifted in May 2023. This course explains the relevant statutes and amendments, dissects the recent cases—Kwong v. United States (Court of Federal Claims) and Abdo v. Commissioner (U.S. Tax Court)— holding that the COVID-19 emergency suspended tax-related deadlines and interest, and explores various potential avenues for relief, from refunds of interest overpayment to class actions seeking interest from the government on overpayments.
This course will:
For more information, click here.
About Andy
Andy brings to every engagement the conviction that all significant tax matters are valuation matters. Drawing on a dynamic background that spans tax law, accounting, finance, and securities, he leverages that fluency by teaming with clients and their financial, economic, valuation, and industry experts to develop comprehensive litigation strategies. Andy has significant experience in conservation easement litigation and preparing for, defending, and resolving complex tax controversies and other valuation matters.
About Gray
Gray is an experienced and accomplished appellate advocate who represents clients facing both civil and criminal tax penalties. He is board-certified as an expert in appellate practice by the Florida Bar Association and accepts cases in a wide variety of disputes in addition to tax.
