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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…
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,…
A recent federal court decision may reopen the door to refunds of COVID-era tax interest and penalties that many taxpayers assumed were lost for good. In Kwong v. United States, No. 23 267 (Fed. Cl. Nov. 25, 2025), the U.S. Court of Federal Claims held that the COVID-19 disaster declaration triggered a mandatory suspension of…
The IRS is considering a potential overhaul of its Voluntary Disclosure Practice (VDP). This comes after the IRS formally ended the Offshore Voluntary Disclosure Program (OVDP) in 2018. Since then, taxpayers with willful offshore reporting failures must use the IRS Criminal Investigation (CI) VDP, which lacks much of the structure and certainty afforded under the…
On January 16, 2026, the U.S. Court of Appeals for the Fifth Circuit issued a split decision (2–1) in Sirius Solutions v. Commissioner, a case with significant implications for partnership taxation. The ruling addresses the scope of the self-employment tax exclusion under Internal Revenue Code §1402(a)(13) and could reshape tax planning for limited partners in…
