This CLE examines recent developments in IRS penalty and interest enforcement arising from the COVID-19 emergency period, with particular attention to the implications of the Kwong and Abdo cases, which challenge whether the IRS may assess late payment penalties and interest during a federally declared emergency. The program provides a detailed analysis of Internal Revenue Code § 7508A and its statutory framework for suspending certain tax deadlines and granting administrative relief during disaster periods. Participants will explore the legal arguments supporting expanded penalty and interest abatement, as well as the procedural requirements for raising, preserving, and asserting these claims in tax controversy matters. The course also addresses practical strategies for engaging with the IRS and pursuing legislative advocacy, including how taxpayers and practitioners can seek administrative relief and encourage congressional action to safeguard taxpayer rights in future emergency declarations.