Stay informed with the latest insights and perspectives from Withum.
The Tax Court’s recent decision in Bowen v. Commissioner provides new guidance on the scope of potential Covid-era refund claims arising from Kwong v. United States. To understand the ramifications of Bowen for taxpayers who are potentially eligible for refunds under Kwong, it is helpful to begin with what the Kwong case established. What Kwong Established The…
IRS Chief Tax Compliance Officer Jarod Koopman recently indicated that the IRS is considering creating a portal, in light of Kwong v. United States, 178 Fed. Cl. 295 (2025), to help taxpayers who may be entitled to refunds of COVID-era interest and penalties submit and track their refund claims. The announcement comes as the IRS…
The appeal many expected has arrived, but the real question is what comes next. For months, taxpayers and practitioners have wondered whether the IRS would ultimately accept the implications of Kwong v. United States or continue defending its interpretation of the COVID-era relief provisions under IRC §7508A(d). We now have part of that answer. The…
Marcus draws on his law background to represent clients in commercial and tax disputes before state courts, Federal District Court and the United States Tax Court, frequently resolving matters through alternative dispute resolution rather than litigation. As an industry thought leader, Marcus contributes to a wide range of publications, helping businesses and individuals navigate high-risk…
The line between tax auditors policing mere civil infractions and investigators pursuing serious tax crimes is beginning to blur in the latest reorganization at the top of the Internal Revenue Service. Jarod Koopman, a long-time and well-known criminal investigator, assumed the role of Chief Compliance Officer in October 2025, and, under the most recent shake-up,…
The federal government shutdown began on October 1, 2025, after lawmakers failed to reach an agreement to extend government funding. Because of this, the Internal Revenue Service has furloughed approximately 35,000 employees – nearly half of its workforce. The furloughs primarily affect enforcement personnel, including Revenue Officers and examiners, while customer service and return processing…
