The July 10th Refund Deadline You Didn't See Coming
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.”
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.
IRS Program #: 7Q3WU-T-00882-26
Frank Agostino
,
Esq.
During his four decades of practicing tax law, Frank Agostino has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers.Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers. Frank defended the taxpayer in a landmark suit, Commissioner v. Zuch, 145 S.Ct. 1707 (2025),in which the U.S. Supreme Court established that the U.S. Tax Court has limited jurisdiction over certain tax enforcement matters. Similarly, in Chai v. Commissioner, 851 F.3d 190, 2nd Cir. 2017, Frank helped to establish that the IRS must obtain supervisory approval before imposing penalties in tax deficiency proceedings. In those and other significant cases, Frank’s challenges to government enforcement processes resulted in precedents that have changed the way the IRSand Tax Court do business, while equipping tax lawyers with new arguments with which to defend their clients. Because of Frank’s stellar reputation in the tax bar, he has been ranked in Chambers in Band 1for Tax: Fraud Nationwide (USA) and in Band 1 for High Net Worth Private Client: Tax. Before joining Kostelanetz, Frank was the president and founder of Agostino & Associates, a well-known tax controversy firm in New Jersey. Prior to entering private practice, Frank was an attorney with the Internal Revenue Service’sDistrict Counsel in Springfield, Illinois and Newark, New Jersey. He also served as a SpecialAssistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, Frank taught tax controversy at Seton Hall University W. Paul StillmanSchool of Business and Rutgers School of Law. He also served as the co-director of the Rutgers Federal Tax Law Clinic. Frank is a frequent speaker and author on tax controversy and litigation matters. He serves on theAdvisory Board of the Journal of Tax Practice and Procedure. Frank is actively involved with theAmerican Bar Association and the New York County Lawyers’ Association. Frank is also the President of Taxpayers Assistance Corp., which provides tax and legal advice to low-incometaxpayers in the NY/NJ area.
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