Free Money on the Table: What the Kwong Case Means for Your Clients

EPISODE · Mar 30, 2026 · 58 MIN

Free Money on the Table: What the Kwong Case Means for Your Clients

from Federal Tax Updates · host Roger Harris, EA and Annie Schwab, CPA

Roger sits down with tax controversy attorneys Jessica Marine and Peter Haukebo of Frost Law to unpack a court ruling most tax pros haven't heard of — but probably should act on before July. The Kwong case could mean significant interest and penalty refunds for clients who filed late during the COVID pandemic, and the window to file a claim is closing fast. They also dig into where ERC cases stand now, including why blanket IRS denials are clogging the appeals pipeline and what practitioners should be watching.SponsorsPadgett -  Contact Padgett or Email Jeff PhillipsGet NASBA Approved CPE or IRS Approved CELaunch the course on EarmarkCPE to get free CPE/CE for listening to this episode.Links mentioned in this episodeChapters(00:00) - Welcome and Setup (02:21) - Meet Frost Law Firm (04:34) - Jessica Tax Court Experience (06:23) - Why Tax Controversy Matters (07:10) - Kwong Case Overview (09:43) - Disaster Deadline Rules (11:37) - Refund Claims and Deadlines (14:18) - IRS Response and Strategy (18:27) - Filing Form 843 Right (26:34) - ERC Meets Kwong (30:05) - ERC Audits and Mediation (31:22) - Appeals Backlog Deadlines (32:25) - Why ERC Won’t Die (33:57) - PEO Refund Roadblocks (37:03) - Where ERC Litigation Stands (39:19) - IRS Service Breakdown (44:27) - Tariffs Ruling Refunds (49:09) - When to Call Frost (54:43) - New SBA EIDL Collections (55:42) - Tariff Refunds Non Importers (57:52) - Final Thanks Sign Off Follow the Federal Tax Updates Podcast on Social Mediatwitter.com/FedTaxPodfacebook.com/FedTaxPodlinkedin.com/showcase/fedtaxpodConnect with the Hosts on LinkedInRoger HarrisAnnie SchwabReviewLeave a review on Apple Podcasts or PodchaserSubscribeSubscribe to the Federal Tax Updates podcast in your favorite podcast app!This podcast is a production of Earmark MediaThe full transcript for this episode is available by clicking on the Transcript tab at the top of this pageAll content from this podcast by SmallBizPros, Inc. DBA PADGETT BUSINESS SERVICES is intended for informational purposes only.

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Free Money on the Table: What the Kwong Case Means for Your Clients

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