Haynes Tax Law

08/31/2026

Another important development in the ongoing Kwong litigation over COVID-era interest relief.

The U.S. Chamber of Commerce has filed an amicus brief in Wepplo v. Commissioner supporting the position that IRC § 7508A requires the COVID disaster suspension period to be excluded when calculating underpayment interest even when the underlying tax liability arose before the COVID suspension period began.

That is significant for taxpayers with older IRS assessments. The Chamber argues that § 7508A’s interest provision operates independently of the provision postponing tax filing and payment deadlines—meaning the IRS should not continue charging interest during the statutory COVID suspension period merely because the tax debt itself predates COVID.

In other words, the Chamber agrees with the broader principle underlying Kwong: COVID-period interest relief is not necessarily limited to liabilities arising during the COVID period.

The Tax Court is now considering this issue directly in Wepplo, and we’ll be watching closely.

Read the U.S. Chamber’s amicus brief:

06/27/2026

See our articles on dealing with the IRS Collection Division at www.haynestaxlaw.com.

05/08/2026

We have a wonderful client who has fallen on extremely hard times. Lost his business, had to file bankruptcy, and is currently homeless. He has a $20,000 balance owed to the Virginia Department of Taxation. We requested an Offer in Compromise, under which our client would pay the Department everything he owed, but at a monthly rate he can "afford" despite living in his truck. The Department rejected his Offer and 30 days later issued a wage levy to take 25% of his net pay. The Offer in Compromise function has been on a steady decline for several years, but this has reached a new low. If it were not for client confidentiality, I would be calling the local news and the Washington Post.

05/08/2026

The IRS Taxpayer Advocate has taken the position that millions of taxpayers may have protective refund claims available under the Kwong and Abdo decisions. If you incurred IRS penalties and/or interest during the period of the COVID disaster (1/20/2020 to 7/10/2023), please take the appropriate steps by 7/10/2026. Our firm has developed proprietary software to assist in the computation and preparation of such claims. If you think you incurred penalties and interest in amounts significant enough to justify the involvement of legal counsel in preparing those claims, please get in touch with us ASAP.

Millions may qualify for refunds on COVID-era penalties and interest. Learn how to claim yours and why you must act before the July 10, 2026 deadline.

04/20/2026

The recent court decisions, Kwong and Abdo, have generated quite a stir in the tax world. If you incurred IRS penalties and/or interest during the period of the COVID disaster (1/20/2020 to 7/10/2023), you may have a limited time to file a claim to recover them. Many firms are struggling to identify and compute such claims. Our firm developed proprietary software that analyzes IRS account transcript data to identify and help compute potential claims.

For more information on the Kwong and Abdo decisions, please see the wonderful article by Kostelanetz attorney, Frank Agostino linked below.

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=6410639

04/02/2026

If you have not yet heard about the Kwong and Abdo cases, they are potentially groundbreaking for taxpayers that have incurred penalties and interest between 1/20/2020 and 7/10/2023. The Court of Federal Claims and the Tax Court ruled that the IRS should not have been accruing interest and certain penalties during that period. Many firms are struggling with how to respond, especially since the IRS has said it will not acquiesce in either decision.

Computing possible claims has presented another significant hurdle that has been causing consternation among practitioners. So we wrote our own software to compute them. If you require assistance computing Kwong/Abdo protector refund claims, we may be able to assist.