Tax filing and payment deadlines falling between January 20, 2020 and July 10, 2023 were automatically extended as a result of the federal COVID-19 disaster declarations, the U.S. Court of Federal Claims ruled in Kwong v. United States, No. 23-267 (Fed. Cl. Nov. 25, 2025). If sustained on appeal, the decision could affect the validity of underpayment interest and/or failure-to-file or failure-to-pay penalties that accrued during this period.

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