This webinar is available for Virtual or LIVE In-Person attendance.
The LIVE class will be held at:
14 Washington Pl #7008
Hackensack, NJ 07601
Kwong & Abdo: Recovering Pandemic-Era Tax Penalties and Interest
2 CE Program | Presented by Frank Agostino, Esq.
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.”
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.
2 Free NY & NJ CLE, CPE and IRS CE/NASBA CPE Credits
IRS Program #: 7Q3WU-T-00882-26
When?
Tuesday, April 21, 2026 · 1:00 p.m.
Eastern Time (US & Canada)
Duration: 2 hours
Price
Free
Language
English
Who can attend
Everyone
Dial-in available? (listen only)
Not available.
Hosted By Tax Practice Pro
Tax Practice Pro is a nationwide provider of live and webinar based Continuing Education. We help tax professionals grow.
Learn more at TaxPracticePro.com
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...