COVID-19 Interest Abatement - Kwong, Abdo and Section 7508A

Section 7508A of the Internal Revenue Code provides relief from certain penalties and interest for taxpayers affected by federally declared disasters. Two recent decisions, Kwong v. United States, 179 Fed. Cl. 382 (2025), and Abdo v. Comm'r of Internal Revenue, 162 T.C. 148 (2024), considered the application of Section 7508A to the COVID-19 pandemic. The decisions strongly suggest that lateness penalties and underpayment interest should not have accrued during the declared COVID-19 emergency, from January 2020 through July 10, 2023. This course covers the legal basis for relief under Section 7508A, the practical implications for your clients, interest and penalty liabilities, and an overview of various procedures to raise and preserve claims.

Learning Objectives:

1. Understand the background and use of disregarding periods, including Sections 7508 and 7508A

2. Understand the holdings of Abdo and Kwong, as well as their practical implications for taxpayers

3. Learn how to raise a claim for relief administratively or in collections due process proceedings