In November 2025, the U.S. Court of Federal Claims issued a landmark ruling in Kuang v. United States. The court held that IRS filing and payment deadlines for tax years 2019 through 2022 were automatically postponed to July 10, 2023, the end of the COVID-19 disaster period plus 60 days.
During that window, the IRS kept charging late filing penalties, late payment penalties, failure-to-deposit penalties, civil penalties, and related interest. Two federal court rulings have since determined those assessments were improper.
The IRS has already refunded $1.2 billion related to this opportunity. The average individual refund is $2,383. The average business refund is $27,645. Amounts range from a few hundred dollars to nearly $100,000.
The deadline to file a protective claim with the IRS is July 10, 2026.
What qualifies:
If you or your business paid IRS penalties or interest between 2020 and 2022, you may be eligible for a refund. HRlogics will file Form 843, Claim for Refund and Request for Abatement, as a protective claim on your behalf. If penalties were assessed but unpaid, HRlogics files the same claim to request abatement so the IRS removes those charges from your record.
Checking your eligibility is free. There is no cost unless a refund is issued. The IRS sends the refund directly to you.
This is an emerging legal position. The IRS is expected to appeal the ruling. Filing now preserves your claim while any litigation is finalized. If you do not file by July 10, 2026, you cannot recover these funds.
Presented in partnership with Advanced Partners. Featuring Bryan Ray, CPA and Director of Tax Recovery and Resolution at HRlogics, and Elizabeth "Biz" Williams, Chief Revenue Officer at HRlogics.