THE 2026 PASS INCLUDES THIS COURSE. 


Do NOT purchase this course separately if you buy a 2026 PASS.


In Kwong v. United States (Fed. Cl. 2025), the court read §7508A(d) to create a mandatory postponement running January 20, 2020 through July 10, 2023. Penalties and interest assessed on returns and payments due inside that window may have accrued improperly — but relief isn't automatic, the IRS hasn't acquiesced, and most claims must be filed by July 10, 2026. This session gives practitioners a practical framework to identify the years at issue and triage which claims justify a protective claim now.


Learning Objectives:

  • Identify the disaster postponement issues in Kwong.

  • Determine which tax years and assessments potentially qualify for relief.

  • Evaluate whether a client needs a protective claim before July 10.


Education Information:


IRS Program Number: NMVBP-T-00343-26-O

Credit Hours: 1 CPE (NASBA); 1 CE (IRS)

Prerequisite: None

Advanced Preparation: None

Program Level: Basic

Delivery Method: Group Internet Based (NASBA); Online Webinar (IRS)

Field of Study: Taxes (NASBA); Federal Tax Topics/Federal Tax Related Matters (IRS)


Instructor: Thomas Gorczynski, EA, CTP, USTCP Learn more about our instructors here.

If you can't attend this live webinar, you'll be automatically enrolled in the on demand version of this course where you can still earn CPE/CE. 

Refund Policy: Refunds processed prior to noon ET the day before the live event are subject to a $25 processing fee. No refunds will be given for live webinars after noon ET the day before the event, but if you are unable to attend the live webinar for any reason you will be given access to the on demand webinar on the same topic.  Click here for more information about our education, refund, and complaint policies. 

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