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MSATP
Maryland Society of Accounting & Tax Professionals
Deadline: July 10, 2026

Kwong v. United States

Tens of millions of taxpayers may be entitled to refunds or abatements of COVID-era penalties and interest — but most must act before July 10, 2026.

Get the complete MSATP Member Guide: court holdings, filing instructions for Form 843, protective claim language, transcripts checklist, and the NTA's latest call to action.

  • Plain-English breakdown of the court's three holdings
  • Step-by-step Form 843 filing instructions
  • Protective claim language you can copy
  • Key dates reference chart & code section glossary

Get the full guide

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Illustration of courthouse columns with American flag and tax documents

What's inside the guide

Everything an MSATP member needs to advise clients on Kwong-related refund and abatement opportunities before the July 10, 2026 deadline.

Court Holdings

All three issues — what was favorable, what wasn't, and why.

Filing Instructions

How to prepare Form 843 with Kwong-specific language.

Protective Claims

Copy-ready language to preserve clients' refund rights.

Practitioner Tips

Pull transcripts, identify affected periods, and act fast.