On February 6, 2026, Western Digital Corp. filed a refund suit in the Court of Federal Claims seeking the refund of $20,764,747 of underpayment interest that accrued during the period of the federally declared disaster during Covid-19. Western Digital Corp. v. United States, No. 26-215. Richard Rubin reported on the case on February 16, in an article entitled Tax Deadlines Accidentally Got Turned Off for Three Years. Now What? This led to blogs being posted about how taxpayers should file claims for refund of interest on tax that accrued during the Covid pandemic. So, what is all the fuss about?
Robert S. Horwitz is a Principal at Hochman Salkin Toscher Perez P.C., former Chair of the Taxation Section, California Lawyers’ Association, a Fellow of the American College of Tax Counsel, a former Assistant United States Attorney and a former Trial Attorney, United States Department of Justice Tax Division. He represents clients throughout the United States and elsewhere involving federal and state administrative civil tax disputes and tax litigation as well as defending clients in criminal tax investigations and prosecutions. In 2022 the Tax Section of the California Lawyers Association awarded him the Joanne M. Garvey Award for lifetime achievement in and contributions to the field of tax law. Additional information is available at http://www.taxlitigator.com
For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com
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