At a Glance: On April 10, 20256 the National Taxpayer Advocate sent this information out in her blog

• Tens of millions of taxpayers may be entitled to refunds or abatements of COVID-19 period penalties and interest.
• Relief will not be automatic - most taxpayers must file refunds clams by July 10, 2026.
• Complex legal developments and a lack of information create a resk that many taxpayers will miss out entirely.
• Without IRS of congressional action,  outcomes may unfaily favor the "well advised" over the "unaware"

What this Webinar Means for You

Under the reasoning of the Kwong decision, you may be entitled to a refund or abatement of certain amounts assessed during the COVID period, including:

• Penalties assessed for failure to timely file returns, failure to pay taxes, or failure to make estimated tax payments;
• Interest that began accruing earlier than it should have, or not at all; and
• Overpayment interest for the 2020–2023 disaster period.

Some practitioners believe that even where the underlying liability arose before the disaster period began, you may not have had to pay interest or penalties during that period. Again, the IRS disagrees. Example 4 in Treas. Reg. § 301.7508A-1(f), states a taxpayer already delinquent before January 20, 2020, does not receive a windfall elimination of pre-disaster penalties and interest. But the regulation will not control the outcome if a court determines the statutory language provided for suspension of all timing penalties and interest accruals, and the Kwong opinion did not address pre-disaster delinquencies.

The bottom line:

You or your clients may be entitled to a refund or reduction of assessed penalties and interest. For taxpayers dealing with financial pressures, these amounts can make a real difference. But most taxpayers must act by July 10, 2026, to request their potential refunds.