Mike Waalkes appeared on the Tax Section Odyssey podcast to discuss the impact of Kwong v. United States.
In this episode of Tax Section Odyssey, Mike discusses the decision with host April Walker and why section 7508A is seeing renewed attention and discussion in the wake of Kwong.
Kwong built on the outcome of Abdo v. Commissioner, 162 T.C. 148 (2024), and has implications for taxpayers with potential liability for interest and penalties accruing during the COVID-19 federally declared disaster. Mike discusses what firms are doing right now to protect their clients’ interests, while awaiting clarification from judicial decisions and IRS guidance.
You can listen to the episode here.
About Mike
Mike is an associate with Kostelanetz LLP. He focuses his practice on civil and criminal tax controversy matters, including audits, promoter investigations, voluntary disclosures, U.S. Tax Court litigation, and criminal tax investigations. Prior to joining the firm, Mike served for two years as a judicial law clerk for Judge Joseph W. Nega of the U.S. Tax Court. Mike is an adjunct professor at Villanova University’s Charles Widger School of Law, where he co-teaches a course on federal tax practice and procedure in the school’s graduate tax program.