Roger sits down with tax controversy attorneys Jessica Marine and Peter Haukebo of Frost Law to unpack a court ruling most tax pros haven't heard of — but probably should act on before July. The Kwong case could mean significant interest and penalty refunds for clients who filed late during the COVID pandemic, and the window to file a claim is closing fast. They also dig into where ERC cases stand now, including why blanket IRS denials are clogging the appeals pipeline and what practitioners should be watching.



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Chapters

• (00:00) - Welcome and Setup
• (02:21) - Meet Frost Law Firm
• (04:34) - Jessica Tax Court Experience
• (06:23) - Why Tax Controversy Matters
• (07:10) - Kwong Case Overview
• (09:43) - Disaster Deadline Rules
• (11:37) - Refund Claims and Deadlines
• (14:18) - IRS Response and Strategy
• (18:27) - Filing Form 843 Right
• (26:34) - ERC Meets Kwong
• (30:05) - ERC Audits and Mediation
• (31:22) - Appeals Backlog Deadlines
• (32:25) - Why ERC Won’t Die
• (33:57) - PEO Refund Roadblocks
• (37:03) - Where ERC Litigation Stands
• (39:19) - IRS Service Breakdown
• (44:27) - Tariffs Ruling Refunds
• (49:09) - When to Call Frost
• (54:43) - New SBA EIDL Collections
• (55:42) - Tariff Refunds Non Importers
• (57:52) - Final Thanks Sign Off

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