Episode
Free Money on the Table: What the Kwong Case Means for Your Clients
- Podcast
- Federal Tax Updates
- Published
- Mar 30, 2026
- Duration seconds
- 3420
- Processing state
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- https://share.transistor.fm/s/192e6e14
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Summary
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. Sponsors Padgett - Contact Padgett or Email Jeff Phillips Get NASBA Approved CPE or IRS Approved CE Launch the course on EarmarkCPE to get free CPE/CE for listening to this episode. Links mentioned in this episode Chapters (00:00) - Welcome and Setup (02:06) - Meet Frost Law Firm (04:19) - Jessica Tax Court Experience (06:08) - Why Tax Controversy Matters (06:55) - Kwong Case Overview (09:28) - Disaster Deadline Rules (11:22) - Refund Claims and Deadlines (14:03) - IRS Response and Strategy (18:12) - Filing Form 843 Right (25:32) - ERC Meets Kwong (29:03) - ERC Audits and Mediation (30:20) - Appeals Backlog Deadlines (31:23) - Why ERC Won’t Die (32:55) - PEO Refund Roadblocks (36:01) - Where ERC Litigation Stands (38:17) - IRS Service Breakdown (43:25) - Tariffs Ruling Refunds (48:07) - When to Call Frost (53:41) - New SBA EIDL Collections (54:40) - Tariff Refunds Non Importers (56:50) - Final Thanks Sign Off Follow the Federal Tax Updates Podcast on Social Media twitter.com/FedTaxPod facebook.com/FedTaxPod linkedin.com/showcase/fedtaxpod Connect with the Hosts on LinkedIn Roger Harris Annie Schwab Review Leave a review on Apple Podcasts or Podchaser Subscribe Subscribe to the Federal Tax Updates podcast in your favorite podcast app! This podcast is a production…