The Court Decision That Opened the Door

The opportunity stems from a federal court ruling issued in late 2025 in a case known as Kwong v. United States. While it didn’t make headlines for most Americans, it has quietly created a significant opportunity for taxpayers.

At the center of the decision is a section of the U.S. tax code that allows the IRS to pause deadlines during federally declared disasters. This rule exists to give taxpayers relief when major events—like hurricanes, wildfires, or national emergencies—disrupt normal life.

The court found that the COVID-19 pandemic qualified as a federally declared disaster for its entire duration, not just isolated periods.

That timeframe stretches from January 20, 2020, through May 11, 2023, plus an additional 60 days after the official end of the emergency.

In simple terms, the court’s interpretation suggests that many IRS deadlines should have been extended all the way to July 10, 2023.