Tax Update

COVID Relief Filing Options

Some taxpayers may have an opportunity to request IRS penalty abatement or refunds tied to the COVID-era disaster relief period thanks to a recent federal court decision, Kwong v. United States. The first step is determining whether your IRS transcripts show penalties or interest during the affected period.

This is not automatic, and not every taxpayer will qualify. If you had IRS penalties, interest, late filing, late payment, or unresolved IRS balances connected to the 2019–2022 tax years, this may be worth reviewing before July 10th, 2026 deadline applies.

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Choose Your Path

Choose the option that best fits how much support you want and whether you already know there may be money to recover.

DIY Option

Self-serve filing


Best for: Hands on taxpayers who want to handle the process themselves.

  • Pull your own IRS transcripts
  • Review penalties and interest
  • Complete form 843 yourself
  • Mail by certified mail

Discovery Review

Dark Horse Eligibility Review


Best for: people who want to know whether an opportunity exists before deciding what to do next

  • POA required
  • We pull your IRS transcripts
  • We identify whether a refund or abatement opportunity appears to exist
  • No filing or monitoring included

Full-Service Filling

Done-for-you support $1,000 / Per Tax Year Per Form


Best for: taxpayers with a confirmed opportunity who expect $3,000+ back per tax year

  • Dark Horse prepares the claim package
  • Protective Claim Form 843 and support materials included
  • Form 843 Refund Request (future once approved)
  • Certified mail & return receipt confirmation

A Potential Refund or Abatement Opportunity But Only If You Act

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Why This Matters

Recent legal developments may create an opportunity for certain taxpayers to request refunds or abatements of IRS penalties and interest assessed during the COVID-era disaster relief period. However, relief is not expected to be automatic for most taxpayers. In many cases, taxpayers need to review IRS transcripts and file a claim to preserve their rights.

The affected window generally centers on IRS penalties and interest tied to the period from January 20, 2020 through July 10, 2023. The most common affected tax years are likely to be 2019, 2020, 2021, and 2022, but eligibility depends on your specific IRS account activity.

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How to Start the DIY Review

Follow these steps to pull transcripts, review potential penalties or interest, and preserve proof of mailing.

  • Step 1: Access Your IRS Account Go to the IRS Online Account or IRS Get Transcript page and sign in using your IRS account or ID.me credentials.
  • Step 2: Download Your Transcripts: Review from 2019 to 2022 and download Account Transcript or Record of Account Transcript, if available.
  • Step 3: Review for Penalties and Interest Look for penalties, interest, payments, credits, abatements, or adjustments during the affected period.
  • Step 4: Determine Whether a Claim May Be Needed If you identify penalties or interest that appear connected to the COVID-era period, you may want to file Form 843 or consult Dark Horse before filing.
  • Step 5: Complete Form 843 Prepare the IRS claim form and include a clear explanation of the refund or abatement request.
  • Step 6: Mail by Certified Mail Mail the signed claim package to the appropriate IRS address using certified mail or another trackable method. Save your signed copy, attachments, certified mail receipt, and delivery confirmation.

FAQs

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Not Sure Where To Start?

If you are unsure whether you qualify, the $500 Discovery Review is the best place to start. Dark Horse will pull your IRS transcripts and identify whether a refund or abatement opportunity appears to exist. From there, you can either self-file or move into Full-Service Filing if the opportunity is worth pursuing.