Have you ever found an amazing strategy for a new tax prospect that they missed in previous years? Even worse, have you realized that you overlooked a client’s eligibility for a credit when you prepared their tax return? Not only that, but you had them make an unnecessary estimated tax payment. Well, it may not be too late for your client and prospect to take advantage of those credits for the year in question. The fate of your client isn’t sealed after filing their tax return. The IRS gives taxpayers a set amount of time to make a claim for a credit on their return. The IRS calls the date that this time sunsets the Refund Statute Expiration Date.

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.


