About this episode

The episode discusses the implications of the Kwong case for tax professionals and their clients, particularly regarding late filings during the COVID pandemic.

Roger sits down with tax controversy attorneys Jessica Marine and Peter Haukebo of Frost Law to unpack a court ruling most tax pros haven't heard of — but probably should act on before July. The Kwong case could mean significant interest and penalty refunds for clients who filed late during the COVID pandemic, and the window to file a claim is closing fast. They also dig into where ERC cases stand now, including why blanket IRS denials are clogging the appeals pipeline and what practitioners should be watching. Sponsors Padgett - Contact Padgett or Email Jeff Phillips Get NASBA Approved CPE or IRS Approved CE Launch the course on EarmarkCPE to get free CPE/CE for listening to this episode. Links mentioned in this episode Chapters (00:00) - Welcome and Setup (02:06) - Meet Frost Law Firm (04:19) - Jessica Tax Court Experience (06:08) - Why Tax Controversy Matters (06:55) - Kwong Case Overview (09:28) - Disaster Deadline Rules (11:22) - Refund Claims and Deadlines (14:03) - IRS Response and Strategy (18:12) - Filing Form 843 Right (25:32) - ERC Meets Kwong (29:03) - ERC Audits and Mediation (30:20) - Appeals Backlog Deadlines (31:23) - Why ERC Won’t Die (32:55) - PEO Refund…

People in this episode

Hosts: Roger Harris, Annie Schwab

Guests: Jessica Marine, Peter Haukebo

Topics covered

• tax controversy
• Kwong case
• ERC cases
• IRS denials
• refund claims
• COVID pandemic

Keywords

• Kwong case
• tax controversy
• IRS
• refund claims
• ERC
• COVID pandemic
• penalty refunds

Sponsors

Padgett

Mentioned in this episode

Organizations: Frost Law, IRS, EarmarkCPE, NASBA

More episodes of Federal Tax Updates

• Don't Cool Off Yet: Post-Tax Season Actions That Matter · April 27, 2026 · 53 min
• Hackers Don't Take Tax Season Off · April 13, 2026 · 59 min
• 40% Through: Filing Season Updates & Legislative Chaos · March 16, 2026 · 55 min
• Tips, Overtime, and Meals: What's Actually Happening This Filing Season · March 2, 2026 · 57 min
• "Hang Up and Call Back" — NAEA President Jennifer MacMillan on This Year's Filing Season · February 16, 2026 · 53 min
• Washington Watch: Filing Season Pressures and Legislative Gridlock · January 26, 2026 · 59 min

Explore listener stats, chart rankings, contacts and more on the Federal Tax Updates podcast page.