Today’s criminals are using more than hooks and lines (more like huge trawling nets), and they are looking for small as well as really big fish. If you think your tax practice is too small to be a target, you’re wrong. And you probably know that. You are probably well aware of the phishing and smishing (using SMS/text messaging) attempts that try to gain access to your firm’s computers and/or computer network.

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.


