There’s no answer yet on Covid-era penalty relief.
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A recent U.S. Tax Court order in Bowen v. Commissioner had tax professionals talking this week. Some tax pros view it as a setback for taxpayers seeking COVID-era penalty and interest relief. But I think that’s an overstatement—the order is narrower than some early reactions suggest.
The taxpayers relied primarily on two previous cases—Abdo v. Commissioner, in which the Tax Court held that the COVID-19 disaster relief provisions automatically extended certain filing deadlines, and Kwong v. United States, in which the Court of Federal Claims concluded that the pandemic postponement period ran through July 10, 2023, potentially supporting claims for refunds...
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