Section 7508A After Kwong: A Procedural Rule That May Have Substantive Refund Consequences
Section 7508A After Kwong: A Procedural Rule That May Have Substantive Refund Consequences
The US Court of Federal Claims’ decision in Kwong v. United States may pose beneficial opportunities for taxpayers and litigation risk for the government by altering the substantive amount of interest, penalties, and recoverable refunds—but taxpayers should ensure they take necessary action before associated deadlines expire.... By: Morgan Lewis