Start with what was charged, what was paid, and when.

July 10, 2026 was important for many potential claims discussed in connection with Kwong v. United States. It was not necessarily the last possible filing date for every later payment. Before relying on a date, identify the taxpayer, tax period, exact charge, return-filed date, and every payment, credit, or offset date and amount.

First, identify what you are asking the IRS to do

  • Refund an amount already paid: the ordinary filing period is generally the later of three years after the related return was filed or two years after payment. A separate lookback rule can limit which paid amounts are reachable.
  • Remove or reduce an unpaid amount: this is generally an abatement question, not the same paid-refund timing question.
  • Change the underlying return: Form 843 may not be the right route; an original or amended return may be required.

Understand the paid-refund timing framework

Make one fact sheet

Record the taxpayer, tax period, notice or transcript charge, actual return-filed date, evidence of any filing extension, each payment/credit/offset date and amount, and the remaining unpaid amount. Keep paid and unpaid portions separate.

Then choose a filing channel—not a result

The IRS currently offers a narrow electronic Form 843 route for certain individual Kwong-related claims involving fully paid interest and penalties. That is a submission option, not an IRS acceptance of the legal theory or a guarantee of relief.

Choose a Form 843 filing path · Read the dated Kwong status note