Karen Kelly and Gray Proctor will present a CLE webinar for BARBRI on May 26, 2026, at 1 p.m. ET, exploring the legal basis for COVID-19 penalty and interest relief under Internal Revenue Code Section 7508A and explaining why July 10, 2026, is now the critical deadline for tax practitioners and their clients.
Karen and Gray will draw on recent Tax Court and Court of Federal Claims decisions, including Abdo v. Commissioner and Kwong v. United States, to explain how mandatory disaster relief provisions apply to interest, additions to tax, and limitations periods during COVID-19.
The decision in Kwong v. United States may provide significant relief from penalties and interest incurred or paid during the COVID-19 period, and its impact is far-reaching. Although an appeal is anticipated, individuals and businesses assessed underpayment penalties and interest for the years 2020 through early July 2023 may want to consider taking immediate action to secure refunds. Refund claims and requests for abatement are time-barred and must be filed by July 10, 2026.
Filing Form 843, Claim for Refund and Request for Abatement, is required to request relief, and completing the form properly is key. Applicants must consider whether the request is a refund claim or an abatement request, identify the covered tax types and years, and calculate recoverable amounts. IRS's varying quarterly interest rates and the multiple tax periods covered can be problematic.
Learn more and register here.
About Karen
The former acting head of the Justice Department’s Tax Division, Karen joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients adverse to the government, including in criminal matters, and state and federal civil tax controversies.
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.
