Protective claims, client alerts and Kwong: A practitioner playbook

About this episode

The episode discusses the implications of Kwong v. United States for CPA firms, focusing on client communications and risk management in light of recent legal developments.

In this episode of the Tax Section Odyssey podcast, host April Walker is joined by Michael Waalkes of Kostelanetz LLP to discuss Kwong v. United States and why it has become a practical, time-sensitive issue for CPA firms after filing season. The episode discusses the facts of the case and what it held at a high level, why Sec. 7508A's COVID disaster relief period (through July 10, 2023) is driving renewed attention, and how the reasoning may affect deadlines, refund-suit timing, and potential interest/penalty arguments for certain clients. The conversation focuses on what firms are doing right now — client communications, internal triage, documentation, and risk management — along with how to think about tools like client alerts and protective claims while the law and potential IRS guidance continue to develop. Questions answered in this episode: What did Kwong v. United States actually hold, and why did it is a "post–April 15" priority for firms? How does Sec. 7508A's COVID disaster relief period (through July 10, 2023) affect statutes of limitation and other key deadlines? Which clients and fact patterns should firms' triage that might be affected by this ruling? What's the…

People in this episode

Host: April Walker

Guest: Michael Waalkes

Topics covered

• Kwong v. United States
• COVID disaster relief
• CPA firms
• client communications
• risk management
• protective claims

Keywords

• Kwong v. United States
• COVID disaster relief
• CPA firms
• protective claims
• client alerts
• risk management
• refund-suit timing
• interest arguments

Mentioned in this episode

Organizations: Kostelanetz LLP, AICPA, CIMA

More episodes of Tax Section Odyssey

• AICPA experts discuss minimum standards for tax preparers · March 18, 2026 · 17 min
• 2025 filing season: What clients are getting wrong (and how to respond) · March 13, 2026 · 25 min
• Tariffs on Trial: What the Supreme Court Ruling Means for Tax Practitioners · March 6, 2026 · 20 min
• Trump Accounts are coming — and you need to be ready · February 6, 2026 · 20 min
• Name, image, likeness — and taxes: What NIL means for student athletes and CPAs · January 30, 2026 · 27 min
• Intentional tax practice — Setting the course for 2026 · January 9, 2026 · 19 min