The July 10th Refund Deadline You Didn't See Coming
This webinar is available for Virtual or LIVE In-Person attendance.
The LIVE class will be held at: TBD
Tax Professionals that attend are encouraged to accept a pro bono tax controversy case assignment from NYCLA, an ABA-sponsored Tax Court Pro program or a NY or NJ low-income Tax Clinic.
Kwong & Abdo: Recovering Pandemic-Era Tax Penalties and Interest
This Program Teaches You How to Turn COVID-Era IRS Payments Into Refund Claims
Two landmark decisions — Kwong v. United States (2025) and Abdo v. Commissioner (2024) — have fundamentally changed the treatment of federal tax penalties and interest during the COVID-19 disaster period.
The takeaway is simple, but powerful:
From January 20, 2020 through July 10, 2023, federal tax penalties and interest were mandatorily suspended under IRC § 7508A(d). That means many taxpayers overpaid — and those amounts may now be recoverable.
The clock is ticking:
For most taxpayers, the refund claim deadline is July 10, 2026.
If you represent clients who paid penalties or interest during this period, this is not optional knowledge — it is an actionable opportunity.
What You Will Learn
This program provides a complete, practitioner-ready framework to:
- Identify clients eligible for penalty and interest refunds
- Apply the holdings of Kwong and Abdo with confidence
- Compute refund amounts using IRS transcripts and AI tools
- Prepare and file Form 843 claims correctly and defensibly
-Navigate examination, appeals, CDP, and Tax Court implications
-Incorporate advanced strategies including:
- IRC § 6404(e) interest abatement
- § 6603 deposits to stop interest accrual
- Overpayment interest claims under the Fleisher theory
- Address multi-year and cumulative claims strategies
- Evaluate state-level considerations (including NY and NJ)
What Makes This Program Different: This is not a theoretical discussion. This is a complete implementation system.
Attendees receive a fully developed toolkit that takes them from: “I think this applies” → “I filed the claim.”
IRS Program #: 7Q3WU-T-00882-26
Frank Agostino
,
Esq.
Frank Agostino is one of the most accomplished tax controversy attorneys in the country, with more than four decades of litigation experience and a string of landmark victories that have reshaped IRS enforcement and Tax Court procedure — including Commissioner v. Zuch before the U.S. Supreme Court (2025) and Chai v. Commissioner in the Second Circuit (2017).
Because of Frank’s stellar reputation in the tax bar, he has been ranked in Chambers in Band 1 for Tax: Fraud Nationwide (USA) and in Band 1 for High Net Worth Private Client: Tax.
A former IRS District Counsel attorney and Special Assistant U.S. Attorney, Frank has also taught tax controversy at Seton Hall and Rutgers Law, and currently serves on the Advisory Board of the Journal of Tax Practice and Procedure.
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