Webinar Preview: Kwong and Abdo Impact on IRS Penalties and Interest

National Association of Tax Professionals (NATP)
National Association of Tax Professionals (NATP)May 29, 2026

Why It Matters

The decisions could materially reduce tax liabilities for many COVID‑19‑related filings, making timely penalty‑abatement strategies a competitive advantage for tax advisors.

Key Takeaways

  • Recent court rulings reshape IRS disaster relief authority.
  • Penalty and interest calculations may change for COVID‑19 disaster period.
  • Refund and abatement opportunities depend on revised statute of limitations.
  • Identifying affected clients requires new compliance screening methods.
  • Form 843 filing could become essential for penalty relief.

Summary

The NATP webinar will examine recent court decisions—Kwong and Abdo—that raise fresh questions about the IRS’s authority to grant disaster relief and the rights of taxpayers whose liabilities stem from the federally declared COVID‑19 disaster period.

The presenters explain how the rulings could alter the calculation of penalties and interest, shift the applicable statute of limitations, and open new avenues for refunds or abatement. They illustrate how the decisions reinterpret the Treasury’s disaster‑relief provisions, potentially reducing assessed penalties and lowering accrued interest for eligible filers.

“Tax professionals must reassess client exposure now,” says the webinar host, noting that filing Form 843 may become a critical tool for seeking penalty relief. Real‑world examples include a small business that previously missed a refund deadline but could now claim it under the revised limitations.

For practitioners, the session offers a roadmap to identify affected clients, evaluate the financial impact, and implement timely strategies. As litigation continues, staying abreast of these rulings will be essential to protect taxpayer rights and advise clients confidently.

Original Description

Recent decisions in Kwong v. United States from the U.S. Court of Federal Claims and Abdo v. Commissioner from the U.S. Tax Court could significantly affect IRS disaster-relief authority, taxpayer rights and certain penalty and interest assessments tied to the COVID-19 federally declared disaster period.
This session will break down the courts’ reasoning in Kwong and Abdo and explore what those decisions may mean for IRS enforcement authority, penalty abatements, refund claims, interest calculations and statute-of-limitations analyses.

Comments

Want to join the conversation?

Loading comments...