Potential new opportunities for COVID 19 period interest and penalty refunds following Kwong and Abdo

Recent judicial decisions in Kwong v. United States (Court of Federal Claims 2025) and Abdo v. Commissioner (Tax Court 2024) raise the possibility of a potential time sensitive opportunity for certain taxpayers to recover interest and penalty amounts that accrued during the COVID 19 national disaster period. Taxpayers who paid underpayment interest or failure to file or failure to pay penalties within the last two years which are attributable to the COVID-19 national disaster period, i.e.,... By: Eversheds Sutherland (US) LLP