Federal Tax Updates
Federal Tax Updates
Roger Harris, EA and Annie Schwab, CPA
Free Money on the Table: What the Kwong Case Means for Your Clients
57 minutes Posted Mar 30, 2026 at 2:00 pm.
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
Welcome and Setup
Meet Frost Law Firm
Jessica Tax Court Experience
Why Tax Controversy Matters
Kwong Case Overview
Disaster Deadline Rules
Refund Claims and Deadlines
IRS Response and Strategy
Filing Form 843 Right
ERC Meets Kwong
ERC Audits and Mediation
Appeals Backlog Deadlines
Why ERC Won’t Die
PEO Refund Roadblocks
Where ERC Litigation Stands
IRS Service Breakdown
Tariffs Ruling Refunds
When to Call Frost
New SBA EIDL Collections
Tariff Refunds Non Importers
Final Thanks Sign Off
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Show notes
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
(
02:06) - 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
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