A panel of tax controversy experts at the 2026 ABA May Tax Meeting on May 8 discussed two court decisions establishing a mandatory, multi-year suspension of many tax deadlines during the COVID-19 pandemic, laying out a range of potential refund claims and approaching action deadlines for practitioners.
The Mandatory Relief Period Explained
The panel’s discussion centered on IRC § 7508A, which grants the IRS authority to postpone tax deadlines for taxpayers affected by federally declared disasters. Following President Trump’s COVID-19 disaster declaration, which established an incident period “beginning on January 20, 2020, and continuing,” the IRS issued discretionary relief in Notice 2020-23 and Notice 2021-21.
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