I'm just getting into researching the November 2025 Kwong v United States decision by the U.S. Court of Claims, involving penalties and interest assessed during the Covid disaster-declaration period that ran from 1/20/20 through 7/10/23 including a 60-day extension period.  Protective claims for refunds should be filed, for amounts already paid, by July 10 of this year.  I don't have that many clients who paid that much in penalties and interest, but this also may include even ES penalty.  

There are a number of sources with information on this case, many of which are not particularly helpful.  This is from one of them:

Who is eligible for a Kwong refund?

Eligibility under Kwong is broader than many taxpayers initially assumed:

• Individuals and Entities: Includes all individuals, businesses, and nonprofits with obligations due between Jan. 20, 2020, and Jul. 10, 2023.
• Geographic Scope: Because COVID-19 was a nationwide disaster, nearly all U.S. taxpayers meet the qualified taxpayer geographic requirement.
• Pre-existing Accruals: Taxpayers whose original due date preceded Jan. 20, 2020, may still have relief arguments for the portion of interest/penalties that accrued within the disaster period.
• Other Penalties: Estimated tax penalties and certain information-return penalties may also be eligible for protective claims.

https://miltonlawgroup.com/2026/03/27/irs-refunds-kwong-decision-covid-penalties/ 

Has anyone else started tracking down potential beneficiaries of this decision?  Or found good sources for further research?