IRS May Owe Refunds for Coronavirus Fines. Taxpayer Wins in Kwong V. United States

The IRS deadline to claim refunds for pandemic-era late filing penalties is July 10, 2026. Taxpayers must mail Form 843 to recover money or abate current debt.

Key Takeaways
  • Eligible taxpayers must file claims by July 10, 2026 to recover pandemic-era late filing and payment penalties.
  • The relief applies to penalties assessed between January 2020 and July 2023 following a federal court ruling.
  • Claimants must manually mail IRS Form 843 to their regional service center to request refunds or abatements.

(UNITED STATES) — The Internal Revenue Service may owe refunds or penalty abatements to taxpayers who were fined for late filing or late payment during the coronavirus period, and most people seeking that relief must file a claim by July 10, 2026.

The potential relief covers taxpayers who filed a return late between January 20, 2020, and July 11, 2023, paid penalties tied to late filing or late payment during that period, or still owe those penalties. It also reaches some taxpayers who filed an international information return late during the same window.

IRS May Owe Refunds for Coronavirus Fines. Taxpayer Wins in Kwong V. United States
IRS May Owe Refunds for Coronavirus Fines. Taxpayer Wins in Kwong V. United States

Claims are not automatic. Taxpayers generally must submit Form 843, the refund and abatement request form, to recover money already paid or ask the agency to remove penalties still on the books.

The legal basis is Kwong v. United States, a federal court case that held COVID-19 emergency laws extended filing deadlines. That ruling underpins requests for refunds and abatements tied to penalties assessed during the pandemic period.

The decision matters because IRS penalties from those years reached a wide span of returns and payment situations. Anyone who filed late in the covered period, paid late-filing or late-payment penalties, still owes those penalties, or filed an international information return late can fall within the group that may qualify.

Relief turns on the penalty period itself. The window begins on January 20, 2020, and runs through July 11, 2023, the timeframe tied to the emergency laws at issue in Kwong v. United States.

Taxpayers seeking money back or an abatement must act before the filing deadline closes. Claims postmarked by July 10, 2026, qualify if processed timely.

The filing method is old-fashioned. Taxpayers must mail Form 843 to the IRS service center for the location where they file current-year returns; they should not e-file or fax the claim.

The form itself requires precision. Claimants should identify the specific penalties from the eligible period and include the dates, amounts, and tax years tied to each one.

Supporting records matter as well. Taxpayers should attach documents such as IRS notices showing penalties, payment records, or proof of late filing.

The form is available through the IRS at [Form 843](https://www.irs.gov/forms-pubs/about-form-843). Mailing addresses vary by state, and the IRS directs taxpayers to check IRS.gov for the correct service center based on where they file current-year returns.

Tax attorney Maloof Whatley urged taxpayers to move quickly. Taxpayers “should not delay reviewing their situation and considering potential claims for refund and abatement,” Whatley said.

The IRS Taxpayer Advocate Service has also stressed urgency. With the July 10, 2026, deadline fixed, waiting can shut off a claim that otherwise fits within the relief recognized after Kwong v. United States.

People who are unsure which penalties were assessed can review their IRS account online through the agency’s [online account service](https://www.irs.gov/account) or call 800-829-1040. Account information and transcripts can help match notices, payments, and filing dates to the period covered by the ruling.

That is especially relevant for taxpayers whose penalties were paid years ago and are no longer top of mind. A transcript or account review can show whether a late-filing or late-payment penalty landed inside the covered dates and whether a Form 843 claim is worth sending.

International information return penalties also sit inside the potential relief if the late filing occurred between January 20, 2020, and July 11, 2023. Those penalties can be substantial, making the date range and the court ruling central to any review.

The process, while straightforward on paper, leaves little room for vague claims. A mailed Form 843 must tie the request to specific penalties, specific dates, and specific tax years, backed by notices or payment records that show what the IRS assessed or collected.

Taxpayers still carrying unpaid penalties can use the same form to seek abatement instead of a refund. The court ruling in Kwong v. United States supports both routes, one aimed at getting money back and the other at removing amounts still owed.

Anyone planning to file should move before mailing delays crowd the deadline. Claims postmarked by July 10, 2026, remain eligible if processed timely, but the window closes on that date.

People also ask

Answers from VisaVerge guides
Which forms may be eligible for penalty refunds due to Kwong v. United States?

Forms such as Form 5471 or Form 5472 may be eligible for penalty refunds if the due date was legally postponed during the pandemic period.

Read: Kwong V. United States Cites Internal Revenue Code Section 7508A for COVID-19 Refunds
Can taxpayers file their tax return after the April 15, 2026 deadline to avoid failure-to-file penalties?

Yes, filing immediately can stop IRS failure-to-file penalties from continuing to grow, though late-payment penalties and interest may still apply if taxes are unpaid.

Read: IRS Warns Thousands: File Form 4868 by June 16, 2026, to Dodge Failure-To-File Penalties
How can I reduce penalties for missing the April 15, 2026 tax deadline?

Filing your return as soon as possible can reduce the period during which the failure-to-file penalty applies.

Read: Missed April 15, 2026 Tax Deadline? File Now and Use IRS Payment Plans to Cut Penalties
When can taxpayers claim refunds under IRC §6435?

Taxpayers can claim refunds for fuel removed from an approved terminal on or after December 31, 2025.

Read: IRS Allows Refunds on Dyed Fuel Taxes Under IRC §6435
Can taxpayers seek relief from paying interest on late tax returns or payments?

Taxpayers may seek narrow waiver relief for unavoidable circumstances, but the charging mechanism remains largely compensatory and automatic.

Read: Income Tax Act 2025 Tightens Section 234A, 234B, 234C Interest Rules on Late Payments
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Sai Sankar

Sai Sankar is a law postgraduate with over 30 years of experience across direct and indirect taxation, spanning consultancy, litigation, and policy interpretation. At VisaVerge.com he leads coverage of cross-border finance for immigrants and NRIs — U.S. and state income tax, IRS rules, tariffs and trade duties, foreign-asset reporting, gift and estate tax, and retirement accounts like IRAs and RMDs. Sai's legal acumen turns the tangled intersection of immigration and money into clear, actionable guidance for a global audience.

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