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Kwong and Abdo: IRS Penalty and Interest Relief Under Section 7508A

SKU: TAX3300

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Price$50

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Description

This CLE course examines recent developments in IRS penalty and interest enforcement arising from the COVID-19 emergency period, with particular attention to the implications of the Kwong and Abdo cases, which challenge whether the IRS may assess late payment penalties and interest during a federally declared emergency. The program provides a detailed analysis of Internal Revenue Code § 7508A and its statutory framework for suspending certain tax deadlines and granting administrative relief during disaster periods.

Participants will explore the legal arguments supporting expanded penalty and interest abatement, as well as the procedural requirements for raising, preserving, and asserting these claims in tax controversy matters. The course also addresses practical strategies for engaging with the IRS and pursuing legislative advocacy, including how taxpayers and practitioners can seek administrative relief and encourage congressional action to safeguard taxpayer rights in future emergency declarations.

Lecturer Bios

Gray Proctor

Gray Proctor is Counsel at Kostelanetz LLP. An appellate attorney for his entire career, he is one of fewer than 1% of Florida attorneys recognized as a board-certified specialist in appellate practice.

Gray’s issues and appeals practice focuses on rapidly-developing legal disputes that affect large groups of taxpayers as well as appeals in individual cases. He also maintains a general appellate practice covering commercial litigation, criminal law, and other substantive areas. His article describing why the Seventh Amendment applies to tax penalties was recently cited by two amicus parties in Hirsch v. United States Tax Court. He is a frequent speaker and commenter on current events in Tax Notes, Law360, and other periodicals.

Gray graduated from Vanderbilt University Law School in 2007, and then clerked for federal judges in the Southern District of Texas, the Eastern District of Virginia, and the Fourth Circuit. He is admitted to practice in the Tax Court, in district courts in Florida and Georgia, in the First through Sixth and Eleventh Circuit Courts of Appeals, and in the Supreme Court.

Daniel Wharton

Daniel Wharton is of Counsel at Kostelanetz LLP. He focuses his practice on federal tax litigation matters.

Daniel works out of Chicago, IL and previously was an attorney at Todd Welty, P.C. until that firm combined forces with Kostelanetz in June 2024. Prior to joining Todd Welty, P.C., Dan was an associate in the Chicago office of Baker McKenzie, where he defended corporations from IRS examinations, through Appeals, and into Tax Court.

Dan received his B.S. in Economics and his B.A. in Political Science from The Ohio State University, his J.D. from Loyola University Chicago School of Law, and his LL.M. in Taxation from Northwestern University Pritzker School of Law.

National Academy of Continuing Legal Education is an accredited sponsor of CLE across the United States. To view our full accreditation details, please .

Accreditation and CLE Rules for Connecticut

Kwong and Abdo: IRS Penalty and Interest Relief Under Section 7508A

Description

Lecturer Bios

Gray Proctor

Daniel Wharton

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