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Tax Breaks: The No Covid-Era IRS Penalty Relief Answers (Yet) Edition

13 0
01.08.2026

A recent U.S. Tax Court order in Bowen v. Commissioner had tax professionals talking this week. Some tax pros view it as a setback for taxpayers seeking COVID-era penalty and interest relief. But I think that’s an overstatement—the order is narrower than some early reactions suggest.

The taxpayers relied primarily on two previous cases—Abdo v. Commissioner, in which the Tax Court held that the COVID-19 disaster relief provisions automatically extended certain filing deadlines, and Kwong v. United States, in which the Court of Federal Claims concluded that the pandemic postponement period ran through July 10, 2023, potentially supporting claims for refunds of interest and some penalties.

In Bowen, the court did not decide whether the pandemic disaster period extended tax deadlines. Instead, it held that even if those deadlines were extended, the extension would not eliminate accuracy-related penalties, which are based on underpayments rather than missed filing or payment deadlines. The order also didn’t consider the taxpayers' challenge to interest, not because the claim lacked merit, but because the Tax Court concluded it did not yet have jurisdiction to decide that issue since the case is ongoing.

Still, Bowen offers insight into how one Tax Court judge views the relationship between COVID-19 disaster relief and accuracy-related penalties, while leaving the broader questions open. Stay tuned (I’ve predicted a SCOTUS review on this whole family of cases and stand by that).

Another issue drawing attention this week was access to Social Security field offices. A group of Democratic senators is demanding answers from Social Security Commissioner Frank Bisignano after reports that some Social Security field offices stopped offering in-person services. In a letter this week, the senators questioned whether those reported closures conflict with Bisignano's pledge to keep every field office open. While many routine transactions can be completed online, more complicated matters—such as survivor benefits, some disability claims, and appeals—often require speaking with an agency employee, making access to local offices important.

The inquiry comes while Bisignano also oversees day-to-day operations at the IRS as the “CEO”, raising questions about customer service at two of the federal government's largest public-facing agencies. The senators point to staffing shortages and employee reassignments as contributing to service disruptions, while the Social Security Administration disputes that characterization. The agency sent a statement to Forbes stating that “None of SSA’s field offices are closed or offering limited service due to staffing issues.” Any temporary closures or service limitations, the agency says, are due to renovations, maintenance, or other facilities-related problems rather than workforce shortages.

Outside of the tax world, one of the biggest stories focused on FIFA’s plan to sell a stake in a new company that would control the commercial operations of the World Cup and other major competitions. The move has triggered fierce opposition from UEFA, which governs soccer in Europe, and CONCACAF, which governs soccer in North America, Central America, and the Caribbean.

Under the proposal, the new company, FIFA Forward Enterprise, would manage broadcast, sponsorship, licensing, hospitality, and ticketing rights, and outside investors led by Thrive Capital (founded by Josh Kushner) would receive a share of future returns. FIFA says the deal could generate substantial new funding, but critics argue that introducing private investors could shift the organization away from its mission to promote the global development of soccer.

The proposal also raises tax and governance questions. FIFA is organized as a........

© Forbes