TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

We are pleased to announce that Melissa Briggs along with Justin Elanjian (Tax Managing Director, Frost Law), Lisa O. Nelson (Managing Partner, Taylor Nelson Amitrano) and Philip J. Wilson (Managing Director, CBIZ) will be speaking on Beyond Kwong: Refund Claims and Best Practices for Preserving Taxpayer Rights at the upcoming St. Louis Summer Tax Summit being held at the Missouri Athletic Club on Tuesday, August 25, 2026, 3:20 p.m. – 4:10 p.m. (CT).

The Court of Federal Claims’ decision in Kwong v. United States has sparked renewed interest in COVID-era refund opportunities and raised important questions about the scope of mandatory postponement relief under IRC § 7508A. Practitioners are still actively evaluating whether taxpayers may be entitled to refunds of penalties and interest, as well as whether the reasoning of Kwong could extend to other missed refund claims, amended returns, refundable credits, and other time-sensitive tax benefits.

This panel of attorneys and CPAs will examine the current status of Kwong, the government’s appeal, and emerging guidance from the National Taxpayer Advocate regarding protective refund claims. Panelists will discuss best practices when preparing Forms 843 and other protective claims, statute of limitations concerns, and practical considerations for taxpayers seeking refunds through administrative claims and/or refund litigation.

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Melissa Briggs is a Principal of Hochman Salkin Toscher Perez P.C. where she represents clients in civil and criminal tax controversies. Ms. Briggs has over twenty-four years of litigation experience in private, nonprofit, and government practice. Ms. Briggs spent over nine years as an appellate attorney for the U.S. Department of Justice, Tax Division, Appellate Section. She served almost seven years as an Assistant United States Attorney with the United States Attorney’s Office for the Central District of California’s Tax Division. She began her legal career as a law clerk to the Hon. Phyllis A. Kravitch on the United States Court of Appeals for the Eleventh Circuit. 

Ms. Briggs is a fellow of the American College of Tax Counsel; American Bar Association, Tax Section Loretta Collins Argrett Fellowship Mentor; vice-chair of the California Lawyer’s Association Tax Section, Tax Practice and Procedure Committee, and active member of the Women Lawyers Association of Los Angeles.  

For more information, please contact Melissa Briggs at briggs@taxlitigator.com.