You may have been charged improper IRS penalties & interest.

A recent federal court decision (Kwong v. United States, November 2025) interpreted a provision of the tax code (IRC §7508A(d)) in a way that may have postponed certain IRS filing and payment deadlines during the COVID-19 national emergency. The disaster period ran from January 20, 2020 through July 10, 2023. Because penalties and interest only accrue after a deadline passes, various tax practitioners believe certain penalties and interest charged by the IRS during this period may have been improper. If you or your business paid penalties or interest to the IRS during this window, you may be entitled to a refund.

The legal basis is IRC §7508A(d), as interpreted by the Kwong v. United States decision. This provision of the tax code governs the postponement of tax-related deadlines during presidentially declared disasters. The Kwong decision interpreted this provision in a way that may have extended filing and payment deadlines — and therefore prevented penalties and interest from accruing — throughout the COVID-19 national emergency period from January 20, 2020 through July 10, 2023.

No, the IRS has the right to appeal the Kwong decision and most tax practitioners believe the IRS will appeal. Since the decision is not final, filing a protective claim does not guarantee a refund, but it preserves your right to a refund if the IRS penalties and/or interest are finally confirmed to be improper. If you do not file by your specific deadline, you will permanently lose your right to a refund.

A protective claim is a formal filing with the IRS that preserves your right to request a refund while a legal issue is still being resolved. Based on current interpretations of the applicable rules, many taxpayers should consider filing protective claims by July 10, 2026. After this date, you may permanently lose your right to a refund — even if the court ruling is ultimately confirmed in taxpayers’ favor.

Under IRC §6511, taxpayers generally have three years from the date a tax return was due to file a claim for refund. Because the last affected deadline under IRC §7508A(d) was July 10, 2023, the three-year lookback period for many taxpayers expires on or around July 10, 2026. After this date, you may permanently lose your right to a refund — even if the court ruling is ultimately confirmed in taxpayers’ favor.

There are no upfront costs. WonderTrust operates on a 100% contingency basis. Our fee is a percentage of the refund or abatement we recover for you. If we don’t recover anything, you pay nothing. No retainers, no hourly fees, no hidden costs — ever.

Many businesses and individuals who were assessed IRS penalties or interest connected to deadlines occurring between January 20, 2020 and July 10, 2023 may be eligible. This includes corporations, partnerships, LLCs, S-corps, sole proprietors, and individual taxpayers. Self-employed individuals and freelancers who paid estimated tax penalties are specifically covered. Eligibility depends on the specific type of penalty or interest and the underlying facts.

Yes, self-employed individuals and freelancers may be eligible. If you filed a Schedule C and were assessed estimated tax penalties under IRC §6654 during the covered period (January 20, 2020 through July 10, 2023), you may have a claim. The Kwong decision and IRC §7508A(d) apply broadly to individuals, not just businesses.

With your approval, WonderTrust is granted view-only access to your tax transcripts. This means we can review your information, but we cannot make changes, file returns, or alter your account in any way. You can revoke this authorization at any time.

WonderTrust is focused on helping entrepreneurs, business owners, and individuals identify and pursue potential financial recovery opportunities. Our team works closely with experienced professionals in tax, finance, and government program analysis — with a track record of helping American businesses and individuals recover what they’re owed.