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.
Recommended Webinars
Cut the Cost: Winning IRS Penalty Abatement Requests
2 IRS CE/x2 CTEC CE/2 NASBA CPE*
"Our best deal is always to become a monthly subscriber" *Self-Study recording not available for NASBA CPE credit.
Cut the Cost: Winning IRS Penalty Abatement RequestsFreedom of Information Act Secrets: Get the IRS to Open Up
1 IRS CE offered On-demand
"Our best deal is always to become a monthly subscriber" *Self-Study recording not available for NASBA CPE credit.
Freedom of Information Act Secrets: Get the IRS to Open UpLost in Translation: Making Sense of PFIC Rules & Form 8621
2 IRS CE/2 NASBA CPE*
Only available for TPP unlimited CE subscribers. "Our best deal is always to become a monthly subscriber" *Self-Study recording not available for NASBA CPE credit.
Lost in Translation: Making Sense of PFIC Rules & Form 8621Intro to IRS Collections
2 IRS CE/2 CTEC CE/2 NASBA CPE*
This basic-level online training session will cover the origin of federal tax liabilities and the basics of the IRS Collections process. We also cover the basics of the major resolution options we have available to us as practitioners to help our clients. This is a 2-hour webinar that will lightly touch on a number of topics relevant to the process of resolving client tax debts. You will leave this session with an understanding of the overall IRS Collections case work process and be better positioned to evaluate client situations for appropriate resolution.
Intro to IRS CollectionsStatutes of Limitations: ASED/RSED/CSED
2 IRS CE/2 CTEC CE/2 NASBA CPE*
"Our best deal is always to become a monthly subscriber" *Self-Study recording not available for NASBA CPE credit.
Statutes of Limitations: ASED/RSED/CSEDFinancial Analysis - 2025
2 IRS CE/2 CTEC CE/2 NASBA CPE*
"Our best deal is always to become a monthly subscriber"*Self-Study recording not available for NASBA CPE credit.
Financial Analysis - 2025Schedule C: What to Expect
2 IRS CE/2 CTEC CE/2 NASBA CPE*
"Our best deal is always to become a monthly subscriber" *Self-Study recording not available for NASBA CPE credit.
Schedule C: What to ExpectWherein IRS and AML meet
2 IRS CE/2 CTEC/2 NASBA CPE*
Any money services transaction business--such as a check cashing business--has to have a strong anti-money laundering (AML) program. The IRS's SB/SE division audits these businesses every couple of years. This course will review the basics of a strong AML program and what to do when the IRS letter comes.
Wherein IRS and AML meetThe Federal Rules of Evidence in Tax Cases – Part II
3 Free NY & NJ CLE, CPE and IRS CE/NASBA CPE Credits
This webinar is available for Virtual or LIVE In-Person attendance. 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.
The Federal Rules of Evidence in Tax Cases – Part II
Hmm...nothing here yet.
