Kwong Case Explained: A Limited-Time IRS Penalty Refund Opportunity

Understanding the Kwong Case

In this episode of Traction with the Tiger, Tax Partner Chris Wittich discusses the recent Kwong case and the potential refund opportunities it may create for taxpayers who paid IRS penalties during the COVID-19 period.

Background of the Court Ruling

Chris explains the court’s ruling, why it matters, and the IRS’s ongoing appeal. He also discusses how the decision could affect taxpayers who paid penalties between January 20, 2020, and July 10, 2023.

Who May Be Eligible for an IRS Penalty Refund

The episode explores which individuals, businesses, trusts, estates, and nonprofits may qualify for relief, as well as the tax years most likely to be impacted.

Common Penalties That May Qualify

Topics include late filing penalties, late payment penalties, estimated tax penalties, and other IRS penalties that may be eligible for a refund claim.

How to File a Refund Claim Using Form 843

Chris walks through the process of filing a refund claim using Form 843 and explains what taxpayers should consider before pursuing a claim.

Important July 10, 2026 Deadline

With a limited window to act, Chris highlights why the July 10, 2026 filing deadline is critical and what taxpayers need to know before time runs out.

Risks, Uncertainties, and Key Takeaways

The episode concludes with a discussion of the uncertainties surrounding the IRS appeal, potential refund timelines, and practical considerations for taxpayers evaluating whether filing a claim makes sense.