Learn How to Recover IRS Late Fees & Interest
What if I told you that for up to 1,268 days, the IRS technically had no authority to charge you a single penny in late fees or interest?
On Nov. 25, 2025, the Court of Federal Claims delivered a landmark ruling in Kwong v. United States. The court ruled that due to the COVID-19 disaster declaration, federal tax deadlines were mandatorily and automatically postponed from January 20, 2020, all the way to July 11, 2023.
For your clients, this isn't just a legal curiosity—it could be a massive refund or abatement opportunity. If they paid failure-to-file penalties, failure-to-pay penalties, or underpayment interest during that window, the IRS might be sitting on their money.
Join Frost Law’s Peter Hakebo, Esq., and Jessica Marine, Esq., who was recently quoted in USA Today on this case, this Wednesday, March 25th at 1:30 PM as we discuss Kwong’s financial implications for taxpayers.
To receive CPE credit for attending this event, please follow the link here.
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Learning Objectives:
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Evaluate IRS audit trends and what is occurring in recent audits
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Discuss latest intelligence and insights from recent -government reports and court rulings
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Explain IRS appeals process and new opportunities for alternative dispute resolution to move claims forward
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Identify the "Two-Year Trap" and why an IRS Notice of Disallowance could cost a business a refund
CPE Credits: 1.0
Field of Study: Taxes
Course Level: Basic
Who Should Attend: CPA - small firm, CPA - medium firm, CPA - large firm, Bookkeeper, CFO / Controller, Small Business Owner
Prerequisites: None
Advanced Preparation: None
Description:
Even though the pandemic is a distant memory, a lot of ERC money remains at stake. Peter and Rebecca will discuss recent government reports, court decisions, and observations on how the IRS Appeals office is handling protested audit claims, including the opportunity for alternative dispute resolution procedures. Most importantly, they will discuss critical timing considerations like the “Two-Year Trap” following an IRS disallowance that could cost businesses a chance to get an ERC refund.
Refunds & Cancellations: This course is offered free of charge. Therefore, no refunds are required in the event of a cancellation for any reason. In the event that ALFI must cancel a session, participants will be contacted via the email address used to register their account.
Complaints: For complaints or concerns, please contact info@alfi.org.
The Accounting, Legal, Finance Institute, LLC (ALFI) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE sponsors through its website: www.nasbaregistry.org.
About the Speakers
Peter Haukebo is a tax attorney and a Partner in the Tax Controversy practice group at Frost Law. Since 2020, Peter has leveraged his background in tax and corporate law to work with business owners throughout the U.S. to help them claim much-needed relief from PPP, EIDL, and the Employee Retention Credit (ERC). His familiarity with the ever-changing tax code and recent legislation allows him to provide second opinions for businesses even if they already filed a claim so that the business owner can properly maximize their tax credits received. His efforts have helped inform hundreds of business owners on the intricacies of ERC and allowed many to claim significant refundable tax credits.
Jessica Marine is a Partner at Frost Law with over 18 years of experience in federal and state tax controversy. A former Deputy Clerk of the U.S. Tax Court, Jessica brings an insider’s perspective to tax litigation and IRS collections, having previously spearheaded the Court’s case services division. Her deep technical knowledge of tax practice and procedure allows her to navigate complex court rulings—like Kwong v. United States—to identify high-stakes refund and abatement opportunities for her clients. Jessica has also shared her expertise as an educator, teaching Tax Practice & Procedure at the University of Baltimore School of Law.