About the Course
Introduction
This webinar will explore the legal basis for COVID-19 penalty and interest relief under Internal Revenue Code Section 7508A and explain why July 10, 2026 is now the critical deadline for tax practitioners and their clients. Our panel of astute tax attorneys will draw on recent Tax Court and Court of Federal Claims decisions, including Abdo v. Commissioner and Kwong v. United States, to explain how mandatory disaster relief provisions apply to interest, additions to tax, and limitations periods during COVID-19.
Description
The decision in Kwong v. United States can provide significant relief from penalties and interest incurred or paid during the COVID-19 period. Its impact is far-reaching. Although an appeal is anticipated, individuals and businesses assessed underpayment penalties and interest for the years 2020 through early July 2023 should consider taking immediate action to secure refunds. Refund claims and requests for abatement are time-barred and must be filed by July 10, 2026.
Filing Form 843, Claim for Refund and Request for Abatement, is required to request relief, and completing the form properly is key. Applicants must consider whether the request is a refund claim or an abatement request, identify the covered tax types and years, and calculate recoverable amounts. IRS' varying quarterly interest rates and the multiple tax periods covered can be problematic. Using AI can facilitate the preparation of Form 843; however, tax advisers need to understand how best to utilize this tool and verify its output. Other methods are available for obtaining relief, including collection due process strategies and refund litigation in district court or, where appropriate, the Court of Federal Claims. Businesses, taxpayers, and tax advisers need to act now to garner the benefits of COVID-19 penalty and interest relief.
Listen as our panel of experienced tax controversy attorneys explains how to leverage COVID-19 disaster relief to reduce penalties and interest and outlines practical claim-filing strategies as the relief window closes.
Presented By
The former head of the Justice Department’s Tax Division, Ms. Kelly, joined Kostelanetz after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice at Kostelanetz focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations, including in criminal tax and white-collar matters, and against state and federal criminal charges. Ms. Kelly's practice includes conducting internal investigations, representing legal and tax professionals and their firms in license and regulatory matters, and complex civil and criminal litigation. She most recently served at the Department of Justice as the Acting Assistant Attorney General and delegated component head of the Tax Division. In that capacity, Ms. Kelly supervised all federal civil and criminal tax matters assigned to the Justice Department throughout the country, and more than 300 trial and appellate attorneys.
Mr. Proctor is a board-certified appellate specialist and one of fewer than one percent of active Florida Bar members to hold that designation. He focuses his practice on federal appellate litigation, with particular depth in tax controversy appeals and APA-based challenges to federal agency action. Mr. Proctor is admitted to practice in the Tax Court, in district courts in Florida and Georgia, in the First through Sixth and Eleventh Circuit Courts of Appeals, and in the Supreme Court.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Date + Time
- event
Tuesday, May 26, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Background and statutory framework
II. COVID‑19 disaster relief and Section 7508A
III. Key cases
A. Abdo v. Commissioner
B. Kwong v. United States
C. What remains unresolved
IV. Identifying relief opportunities
A. Eligible taxpayers and covered tax years
B. Penalties, interest, and limitations periods affected
C. Refund versus abatement
V. Obtaining relief
A. Automatic relief framework and documentation
B. Form 843 preparation and filing considerations
C. Collection due process strategies
D. Refund litigation pathways
VI. Risk management and the July 10, 2026 deadline
The panel will cover these and other critical issues:
- Practical strategies for using AI tools to efficiently prepare and support Form 843 claims
- Identifying eligible tax types and relief periods under COVID penalty and interest relief guidance
- Assessing when automatic relief applies and when litigation strategies should be considered
- Managing client expectations and communications as the July 10, 2026 deadline approaches
Learning Objectives
After completing this course, you will be able to:
- Identify penalties, interest, and tax years eligible for COVID‑19 disaster relief under Section 7508A
- Decide between administrative, collection‑based, and litigation pathways for obtaining relief
- Ascertain how to prepare Form 843, Claim for Refund and Request for Abatement
- Determine how the decision in Kwong v. United States impacts COVID relief
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of federal taxation and statutes.
BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
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IRC Section 7508A COVID Penalty and Interest Relief: Eligibility, Covered Periods, and Filing Form 843
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