Am I owed a refund for IRS penalties from 2020 to 2023?
If the IRS charged you penalties or interest on taxes due during COVID, you may be able to get that money back.
A 2025 federal court ruling (Kwong v. United States) found that the IRS improperly charged penalties and interest on tax balances due between January 20, 2020 and July 10, 2023.
The IRS has appealed the decision and disagrees with it, so a refund isn't guaranteed. But you can file a claim now to preserve your right to one if the ruling holds up.
Am I eligible for a refund?
You may be eligible for a refund if all of the following is true:
Your tax payment or filing was due between January 20, 2020 and July 10, 2023
The IRS charged you:
Failure-to-file penalties,
Failure-to-pay penalties, or
Underpayment interest or late-payment interest
You haven't already received a refund or reduction for those charges
Individuals, small businesses, corporations, estates, and trusts may all qualify.
How do I claim my refund?
You'll need to file IRS Form 843 (Claim for Refund and Request for Abatement) directly with the IRS by July 10, 2026.
Form 843 can't be filed electronically; it has to be mailed
If you think you might qualify but aren't certain, you can still file a Form 843 to preserve your right to a refund in case the ruling is upheld.
Form 843 is used for several different purposes (like FICA overpayments), and a Kwong-related claim is just one of them.
Can I file IRS Form 843 in TurboTax?
No. TurboTax doesn't support Form 843.
You can still use your TurboTax account to access your past returns from those years, which can help you gather the information you'll need.
