The IRS Charged Your Business COVID-Era Penalties It Was Prohibited From Collecting
Two federal courts have confirmed it. Now there's a limited window to recover what you were incorrectly charged — before July 10, 2026.
No fee until your refund or penalty abatement is in hand. No risk. No obligation for the initial review.
TIME'S RUNNING OUT TO FILE YOUR ABDO/KWONG REFUND CLAIM!
July 10, 2026 is the deadline - and then it is gone forever.
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The IRS Kept Charging — Even When the Law Said It Couldn't
Federal law — specifically I.R.C. § 7508A, enacted in 2019 — required the IRS to disregard the COVID-19 disaster period when computing the amount of any interest, penalty, or addition to tax. The disaster period ran from January 20, 2020 through July 10, 2023.
The IRS largely ignored this mandate. It continued assessing and collecting penalties and interest as if the disaster period never happened — charging businesses and individuals amounts it was legally prohibited from imposing.
Two federal courts have now confirmed what the statute plainly says:
• Abdo v. Commissioner, 162 T.C. 148 (2024): The U.S. Tax Court held § 7508A(d) unambiguous, self-executing, and mandatory. The IRS's contradictory regulations were invalidated.
• Kwong v. United States, 179 Fed. Cl. 382 (2025): The U.S. Court of Federal Claims confirmed the full disaster period and rejected the IRS's attempt to limit recovery.
What do you do?
The IRS has issued no corrective guidance. The only path to recovery is to file a formal refund claim with all of the associated technical documentation — and the deadline is approaching fast.
This isn't a loophole. It's a court ruling.
The Kwong decision confirmed that July 10, 2026 is the outer boundary for most COVID-era penalty claims. New legislation — P.L. 119-64, signed December 26, 2025 — extended the lookback period, reviving many claims that practitioners had assumed were time-barred.
But the July 10, 2026 deadline is fixed.
After this date, the claims cannot be filed. The IRS is under no obligation to correct the accounts. The money is gone permanently. We are accepting new clients now — the sooner we begin, the more margin we have to build and file a complete, well-documented claim.
We Handle Everything. You Just Say Go.
Our end-to-end process requires minimal time from you and zero upfront cost.
Our end-to-end process requires minimal time from you and zero upfront cost.
Our end-to-end process requires minimal time from you and zero upfront cost.
STEP 1 — AUTHORIZE US
Our end-to-end process requires minimal time from you and zero upfront cost.
Our end-to-end process requires minimal time from you and zero upfront cost.
You sign a Form 8821 Information Request and a Form 2848 Power of Attorney. Those documents give us the authority to access your IRS records and represent you through the entire process.
STEP 2 — WE PULL YOUR TRANSCRIPTS & ANALYZE
Our end-to-end process requires minimal time from you and zero upfront cost.
STEP 2 — WE PULL YOUR TRANSCRIPTS & ANALYZE
We obtain your IRS Account Transcripts directly and conduct a comprehensive penalty analysis across all relevant tax years (2019–2023), covering both your business and personal returns.
STEP 3 — WE BUILD AND FILE YOUR CLAIM
STEP 3 — WE BUILD AND FILE YOUR CLAIM
STEP 3 — WE BUILD AND FILE YOUR CLAIM
We prepare complete Form 843 refund and abatement packages with full legal documentation, classification of each claim, and supporting court authority. We file and manage all IRS correspondence.
STEP 4 — WE REPRESENT YOU
STEP 3 — WE BUILD AND FILE YOUR CLAIM
STEP 3 — WE BUILD AND FILE YOUR CLAIM
We advocate on your behalf through IRS review. If your claim is examined or disputed, we handle the entire process — including disputes and Appeals and, if necessary, provide you with options for Collection Due Process proceedings.
STEP 5 — YOU RECEIVE YOUR REFUND
STEP 3 — WE BUILD AND FILE YOUR CLAIM
STEP 5 — YOU RECEIVE YOUR REFUND
When the IRS acts on your claim, you receive your refund plus overpayment interest or have your outstanding liabilities abated. Our fee is only collected at this point — after you have received your benefit.
don't leave money on the table
If you filed individual or business tax returns during 2020–2023 and were charged penalties or interest, you may be owed a refund.
✓ Failure-to-File penalties (§ 6651) — business or personal
✓ Failure-to-Pay penalties (§ 6651) — business or personal
✓ Payroll tax deposit penalties (§ 6656) — common for employers
✓ Trust Fund Recovery Penalties (§ 6672) — responsible person liability
✓ Estimated tax penalties (§§ 6654/6655)
✓ Information return penalties — W-2s, 1099s (§§ 6721/6722)
✓ Partnership or S-Corp late filing penalties (§§ 6698/6699)
✓ International information return penalties — Forms 5471, 5472, 8865
✓ Accuracy-related penalties (§ 6662) — protective claims available
Not sure if any of these apply? That's exactly what we determine in our free tax transcript review. Don't assume your situation doesn't qualify — the categories are broad, and the potential amounts are often larger than clients expect.
It takes only a few minutes to check.
Experience the Reinsman Difference
Specialist Expertise. Complete Service. Zero Upfront Cost.
EXPERIENCED TAX PROFESSIONALS
EXPERIENCED TAX PROFESSIONALS
EXPERIENCED TAX PROFESSIONALS
We are federally licensed tax practitioners with unlimited practice rights before the IRS — representing clients at every level, from correspondence through examination, Appeals, and Collection Due Process.
END-TO-END SERVICE
EXPERIENCED TAX PROFESSIONALS
EXPERIENCED TAX PROFESSIONALS
From the first authorization to the final refund, we manage the entire process. You are never left to navigate IRS correspondence alone.
BUSINESS + PERSONAL ANALYSIS
EXPERIENCED TAX PROFESSIONALS
BUSINESS + PERSONAL ANALYSIS
We review both entity and individual returns for every client. Many practitioners focus only on business returns and miss significant personal return opportunities. We don't.
100% CONTINGENCY FEE
DEEP TECHNICAL FOUNDATION
BUSINESS + PERSONAL ANALYSIS
No fee until the IRS actions your claim. If we don't find a refund or abatement opportunity, there is no cost. Period.
IRS-REVIEWED CLAIMS
DEEP TECHNICAL FOUNDATION
DEEP TECHNICAL FOUNDATION
These claims are typically reviewed by the IRS before any money is paid. This built-in review process protects you. This limits the risk of paying fees and then having the IRS demand money back.
DEEP TECHNICAL FOUNDATION
DEEP TECHNICAL FOUNDATION
DEEP TECHNICAL FOUNDATION
Our claims are built on the statutory text of § 7508A, the controlling case law (Abdo, Kwong), and current legislative authority (P.L. 119-64). We document every position to withstand IRS scrutiny.
This website is for informational purposes only and does not constitute legal or tax advice. Results vary based on individual circumstances. Past results do not guarantee future outcomes. Consult a qualified tax professional regarding your specific situation. Reinsman Consulting, LLC, Reinsman Business & Tax Advisory, LLC and Reinsman Tax Resolution, LLC are management consulting and tax advisory firms and are not a law firm.
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