This CLE program explores emerging tax controversy issues involving IRS penalties and interest assessments tied to the federally declared COVID-19 emergency period. The course will examine recent litigation, including the Kwong and Abdo cases, and analyze the arguments challenging the IRS’s authority to impose certain late payment penalties and interest while emergency relief provisions were in effect.

Attendees will receive an in-depth review of Internal Revenue Code § 7508A, including its scope, statutory purpose, and application to disaster-related extensions and administrative relief. The program will also discuss procedural and strategic considerations for practitioners seeking penalty and interest abatement, preserving claims in ongoing disputes, and advocating before the IRS. In addition, the course will address broader policy implications and potential legislative efforts aimed at clarifying taxpayer protections during future national emergencies and disaster declarations.