June 12, 2026

COVID Case Relief

During COVID-19, the IRS announced special disaster-style relief that moved certain federal tax deadlines. A recent court case has also caused the IRS and tax professionals to take a fresh look at whether some penalty and interest charges from 2019–2023 were calculated using the wrong “due date.” If the IRS used the wrong date, you may have paid penalties or interest that you didn’t actually owe—and you may be able to request a refund. The due date to submit the proper filing for the relief is July 10, 2026.

This letter is intended to help you understand what to review and what steps to take next.

What changed

Penalties and interest are often based on how many days late something was—late filing, late payment, or late estimated tax payments. During the COVID-19 period, special rules postponed (pushed back) certain tax deadlines. More recently, a court case has supported the idea that some of those postponed deadlines may have lasted longer than many people originally thought.

Bottom line: if your IRS notice treated you as “late” based on an earlier date, there is a chance the penalty and/or interest should be reduced—or removed—and refunded. Keep in mind it is not a guarantee.

What Happened?

In Kwong v. United States, the court ruled that special COVID disaster relief rules extended certain IRS deadlines from January 20, 2020 through July 10, 2023. Because of this extension, some refund claims or refund lawsuits that previously appeared too late may still be timely.

Which IRS charges could be affected?

This issue can potentially affect more than one type of IRS charge, including:

Late filing penalties (you filed a return after the due date)
Late payment penalties (you paid a balance after the due date)
Estimated tax underpayment penalties (the IRS says you didn’t pay enough, soon enough, during the year)

Even if you filed your return on time, you might still have paid interest or an estimated tax penalty that could be worth revisiting.

How to see if this might apply to you

We require that you obtain your own Account Transcripts before we can move forward

Create or log onto your IRS online account that will give you direct access to your tax information
Obtain your Account Transcripts
Identify Penalty and Interest paid from tax years 2019 – 2023.
Add up the total penalties + interest you actually paid for 2019–2023.

What we recommend (and when to contact our firm)

If your total paid IRS penalties + interest for 2019–2023 is MORE than $5,000:
Please contact us. At that level, a professional review is usually worth it. Our fee for this service ranges from $1,500 to $3,000, which includes the analysis and preparation and submission of Form 843. If there is any additional work required, including following up with the IRS, it will be billed based at our hourly rate.

If your total paid IRS penalties + interest for 2019–2023 is UNDER $5,000:
In most cases, you do not need to contact our firm. We encourage a do-it-yourself approach to keep your costs down. To help, we are providing a do-it-yourself packetyou can use as a model.

What is Form 843?

Form 843 is an IRS form used to request a refund or reduction of certain penalties and interest. Think of it as a written request that tells the IRS:

what penalty/interest you are asking about,
the tax year and form involved,
how much you want refunded (or reduced), and
why you believe the charge was incorrect.

The IRS may or may not grant every request. Some requests are approved quickly; others take time or require follow-up. Still, for many taxpayers, Form 843 is a practical way to ask the IRS to fix penalty/interest charges that may have been calculated using the wrong dates.

How long do I have to take action?

IRS must receive Form 843 by July 10, 2026. For a professional review, please contact our office no later than 6/17/2026, if total IRS penalties + interest for 2019-2023 is OVER $5,000.

Caution

Court decisions are subject to further IRS scrutiny, potential no acquiescence, or future limiting guidance, and there is no assurance that the IRS will extend the same treatment to all similarly situated taxpayers. While we believe the position described above is supportable, it could be challenged on examination or in subsequent IRS or judicial developments. As a result, the ultimate outcome of this position cannot be guaranteed. There is also a chance that IRS could automatically provide relief, or provide additional time to file refund claims.

What you can do next

Obtain your Account Transcripts on the IRS website.
Add up total penalties + interest actually paid.
If over $5,000, contact us so we can review your situation and discuss next steps.
Additional references are available on our website. Click on the link in our email signature to gain access to our website.

We know IRS notices can be stressful—especially after the last few years. Our goal is to help you take advantage of any refund opportunity that’s available, while also keeping this simple and cost-effective.