COVID-19 Tax Relief Revisited: Could You Still Have Unclaimed Refund Rights?

COVID-19 Tax Relief Revisited: Could You Still Have Unclaimed Refund Rights?

A Comprehensive Guide to the Kwong Decision, the IRS Appeal, and the July 10, 2026 Deadline

Executive Introduction

There is a good chance you have not thought about your 2020 tax return in years.

Why would you?

For most people, tax compliance follows a familiar pattern. You gather documents, file a return, deal with any balance due or refund, and move on with your life. The tax year ends. The file is closed. Your attention shifts to more immediate concerns.

The years between 2020 and 2023, however, were not ordinary years.

You may have been adapting to remote work for the first time. You may have owned a business that suddenly faced supply chain disruptions, staffing shortages, or mandatory closures. You may have changed jobs, relocated, cared for family members, navigated health concerns, or simply focused on making it through a period of uncertainty unlike anything most people had previously experienced.

 

During those years, tax compliance remained important, but for many people it understandably became one priority among dozens competing for attention.

The years between 2020 and 2023, however, were not ordinary years.

Perhaps you filed a return later than expected.

Perhaps you received an IRS notice and paid it without questioning the details.

Perhaps you intended to file but never got around to it.

Perhaps you assumed that any refund opportunity that once existed had long since expired.

Perhaps you have not looked at an IRS transcript in years.

If any of those situations sound familiar, this guide may be relevant to you.

Not because a court suddenly created a new tax benefit.

Not because the IRS announced a special refund program.

And certainly not because everyone who reads this guide will be entitled to a refund.

Rather, this guide exists because a federal court decision has raised questions about whether certain tax deadlines associated with the COVID-19 federal disaster period were interpreted correctly in the first place.

That decision is Kwong v. United States.

At first glance, Kwong appears to be a highly technical dispute involving the interpretation of Internal Revenue Code Section 7508A, a provision dealing with tax relief during federally declared disasters.

Most people would never have reason to read the case.

Most people should never need to.

Yet beneath the statutory language and procedural arguments lies a question that may be surprisingly relevant to your situation:

Could you still have rights you believed were gone?

That question is now being examined by tax professionals, courts, government officials, and taxpayers across the country.

The answer remains uncertain.

The IRS has appealed the Kwong decision to the U.S. Court of Appeals for the Federal Circuit. Future courts may affirm the decision, narrow its reach, distinguish it from other situations, or reject portions of its reasoning altogether.

 

In other words, the legal story is still being written.

 

Yet while the courts continue their work, another reality remains unchanged.

 

Time continues moving forward.

 

And for many people, that may be the most important part of this entire discussion.

Imagine discovering several years from now that a court ultimately adopted a position favorable to taxpayers.

Imagine also discovering that your opportunity to preserve your rights expired before that decision was issued.

At that point, the legal outcome may matter less than you hoped.

This is why the National Taxpayer Advocate has repeatedly emphasized awareness, review, and timely action.

The issue is not simply whether taxpayers may ultimately win or lose a legal argument.

The issue is whether individuals and businesses understand their situations well enough to make informed decisions before important procedural deadlines expire.

This guide was written with that objective in mind.

You will not find predictions about how the courts should rule.

You will not find promises of refunds.

You will not find sensational claims designed to generate unnecessary urgency.

Instead, you will find a practical discussion of:

  • what the Kwong decision actually says;
  • why it matters;
  •  who may be affected;
  • how to review your IRS records;
  •  why July 10, 2026 has attracted attention;
  •  how refund claims, protective claims, and abatement requests fit into the discussion;
  • what the IRS appeal means;
  • and how to think about your options while the law continues to evolve.

Throughout this guide, one principle will remain constant.

The goal is not to convince you that you have a claim.

The goal is to help you determine whether your situation deserves a closer look.

Because before you can decide whether any action is appropriate, you first need to understand the facts.

And that journey begins with a story most people never expected to follow.

Leave a Reply

Your email address will not be published. Required fields are marked *

Related post
« Aimlon CPA P.C. is a tax, audit, accounting and advisory firm in New York, NY serving business owners and companies in the U.S. and in Europe. The insights and quality services that we provide help our client grow their business sustainably.

This material has been prepared for general informational purposes only and is not intended ti be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice ».