COVID-Era IRS Penalty Refund Claims Still Open — What You Should Do Next

Author: Telma Landhorian, CPA, MBA | | Categories: 2026 Tax Changes , CPA Firm , CPA Insights , CPA Tips , IRS Penalties , IRS penalty refund , IRS Rules 2026 , IRS Tax Refunds , IRS Updates 2026 , Tax Planning , Tax Policy Changes , Tax Reform Updates

Blog by Elite Consulting, P.C.

You may have already heard about a possible tax refund opportunity tied to IRS penalties from the COVID years.

Some taxpayers who paid penalties or underpayment interest during 2020–2022 may still be able to recover money. This opportunity is linked to legal interpretations involving Kwong v. United States, and claims may remain open until around July 10, 2026.

But after the initial news, many people are now asking a more important question:

“What should I actually do about it?”

This follow-up guide gives simple CPA-style insights on how to move forward, what mistakes to avoid, and how to check if you may qualify.

 

Quick Recap: What This Refund Opportunity Is

During the COVID years, many taxpayers:

  • Filed late returns
  • Paid taxes late
  • Received IRS penalties
  • Were charged underpayment interest

Because of pandemic disruptions, courts and tax experts have questioned whether some of those charges were properly applied.

As a result, certain taxpayers may be able to file a claim to recover money paid in penalties or interest.

This is not automatic. You must actively review your records and file a claim if you qualify.

 

Why Many Taxpayers Miss This Opportunity

From a CPA perspective, most missed refunds happen for simple reasons:

1. People forget they paid penalties

Many taxpayers paid penalties years ago and moved on. They do not realize those payments may still matter.

2. IRS notices were lost or ignored

COVID-era mail delays and paper notices mean some people never fully reviewed their IRS account.

3. They assume penalties cannot be refunded

Most people think IRS penalties are final. In many cases, that is not always true.

4. They don’t know how to check records

IRS transcripts are not always easy to understand without help.

 

Step 1: Check Your IRS Account History

The first CPA recommendation is simple: do not guess—check your records.

You should review:

  • IRS account transcripts
  • Notices from 2020–2022
  • Payment history
  • Penalty and interest breakdowns

Your transcript will show exactly what the IRS charged you and when.

If you see:

  • Failure-to-file penalties
  • Failure-to-pay penalties
  • Underpayment interest

You may have something worth reviewing further.

 

Step 2: Identify COVID-Era Timing

Not every penalty qualifies.

This opportunity focuses mainly on:

  • 2020 tax year
  • 2021 tax year
  • 2022 tax year

These years matter because they were heavily affected by:

  • IRS delays
  • Office closures
  • Processing backlogs
  • Emergency tax relief programs

If your penalties fall in these years, they may be worth closer review.

 

Step 3: Understand That Not Every Case Qualifies

A CPA will be very clear here:

Not all penalties are refundable.

Eligibility depends on factors like:

  • Why the penalty was assessed
  • Timing of IRS processing
  • Type of tax issue involved
  • Whether relief rules apply

This is why professional review matters. It is not a simple “everyone gets money back” situation.

 

Step 4: Don’t Wait Until the Deadline

The expected claim window may remain open until around:

July 10, 2026

But waiting is risky.

Here’s why:

  • IRS processing can take time
  • Older records may be harder to access
  • Corrections may require follow-up documentation
  • Many taxpayers will likely file near the deadline

From a CPA perspective, early review is always better.

 

Step 5: Common Mistakes to Avoid

Many taxpayers lose refund opportunities because of avoidable mistakes:

Mistake 1: Throwing away IRS notices

Old letters often contain key penalty details.

Mistake 2: Assuming software already handled it

Tax software does not always flag penalty refund eligibility.

Mistake 3: Not requesting transcripts

IRS transcripts are the most reliable record of what happened.

Mistake 4: Filing without review

Some taxpayers file claims without checking if they actually qualify.

 

Why a CPA Review Matters Here

This is not a standard tax refund situation.

A CPA (Certified Public Accountant) can help you:

1. Read IRS transcripts correctly

Transcripts can be confusing. A CPA knows how to interpret them.

2. Identify eligible penalties

Not all charges qualify. A CPA can separate valid vs non-eligible items.

3. Prepare proper documentation

Refund claims often require supporting records.

4. Avoid delays

Incorrect filings can slow down IRS processing.

5. Maximize recovery opportunities

Some taxpayers have more than one eligible year or account issue.

 

CPA Insight: Who Should Pay Attention First

This opportunity is especially important for:

Small business owners

They often had estimated tax issues during COVID.

Self-employed workers

Income fluctuations led to underpayment penalties.

Investors

Capital gains timing caused unexpected tax balances.

High-income earners

Larger balances often resulted in higher penalties and interest.

 

CPA Insight: What You Should NOT Do

A professional CPA would also warn against:

Don’t assume eligibility

Many cases look similar but qualify differently.

Don’t rush filings

Missing documents can cause delays or rejection.

Don’t rely on rumors

Always verify with IRS records or a tax professional.

Don’t ignore small amounts

Even small penalties may add up across multiple years.

 

What a Strong Action Plan Looks Like

If you are serious about checking this opportunity, here is a simple CPA-style plan:

  1. Pull IRS transcripts for 2020–2022
  2. Highlight any penalties or interest
  3. Organize IRS notices and payment records
  4. Review with a CPA or tax professional
  5. Determine eligibility for refund claim
  6. Prepare documentation early
  7. File before deadline pressure builds

 

Why This Matters Right Now

Many taxpayers are focused on current tax season issues and forget about past years.

But COVID-era tax years still hold unresolved issues for some taxpayers.

Even if you are unsure whether you qualify, reviewing your records now gives you:

  • More time
  • Less stress
  • Better accuracy
  • Higher chance of success

 

Final CPA Thoughts

The COVID-era IRS penalty refund opportunity is real, but it is not automatic.

It requires:

  • Careful review
  • Accurate records
  • Proper filing
  • And often professional guidance

From a CPA perspective, the biggest risk is not missing the opportunity entirely—it is waiting too long or not checking at all.

If you paid IRS penalties or underpayment interest during 2020–2022, now is the time to take a closer look.

A simple review today could uncover money you already paid—and may still be able to get back before the July 2026 deadline.

 



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