Let’s be direct: AI is one of the most powerful capacity tools tax professionals have seen in decades. Used correctly, it buys you time you can reinvest into high-value advisory: planning, structuring, audits, negotiations, strategy, client education, and relationship building. But here’s the catch that you as an elite tax practitioner already understand: aggressive planning requires rigorous defensibility. If you’re going to use AI to accelerate complex planning work, your defense file must be stronger, not weaker. This playbook gives you that: a practical framework that keeps you safe while you scale.

Kwong v. United States: A Pandemic-Era Decision That Could Reshape Tax Deadlines, Penalties, and Refund Opportunities
The 2025 court decision, Kwong v. United States, is quietly gaining traction among tax professionals for exactly these reasons. Its implications could be far-reaching, potentially opening the door to refund claims, penalty abatements, and revived tax deadlines that many assumed were long closed. But there’s a catch: the opportunity to act may be time-sensitive, and the window to preserve claims could begin closing in just a few short weeks. Here’s what the court actually decided and why it matters now.


