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About
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.
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