A penalty of $500 here, $1,200 there. During the worst of the COVID-19 pandemic, the IRS kept its automated penalty machine running even as its own offices went dark, mail piled up unprocessed, and millions of Americans lost jobs or fell seriously ill. Now the agency may owe that money back. But claiming it requires a paper form, a stamp, and action before a hard deadline that is fewer than six weeks away.
The National Taxpayer Advocate has warned that tens of millions of taxpayers may be eligible for refunds of failure-to-file and failure-to-pay penalties assessed during the pandemic years. The general deadline to submit a written refund claim is July 10, 2026. The required document, IRS Form 843, cannot be filed electronically. It must be printed, signed, and sent through the U.S. mail.
As of June 2026, the IRS has not published data on how many people have already filed claims or how quickly those claims are being processed, leaving taxpayers and tax professionals largely guessing about what to expect.
Why these refunds exist
Throughout 2020, 2021, and into 2022, the IRS continued to assess standard penalties on late-filed and late-paid tax returns. That happened even as agency offices were closed, mail delivery was severely disrupted, and pandemic-related hardship was widespread. Many of those penalties were imposed automatically by IRS systems, with no consideration of whether a taxpayer’s lateness was caused by COVID-related disruptions.
Federal law under 26 U.S.C. Section 7508A gives the IRS authority to extend tax deadlines during a federally declared disaster. The COVID-19 national emergency triggered those provisions. Because the statute generally allows taxpayers to file refund claims within a specific window tied to the extended deadlines, the cutoff for many affected filers falls on July 10, 2026. After that date, the right to recover penalties already paid may be permanently lost.
This is not the first round of COVID-era penalty relief. In late 2022, the IRS issued Notice 2022-36, which automatically waived failure-to-file penalties for roughly 4.7 million individuals and businesses who filed certain 2019 and 2020 returns late. Those refunds went out without taxpayers needing to lift a finger. The current deadline applies to a broader set of penalties and tax years that were not covered by that automatic relief, so even people who benefited from Notice 2022-36 may still have additional penalties eligible for abatement.
Who is eligible
Eligibility hinges on several factors. The penalties must have been assessed for tax years affected by COVID-era disaster relief provisions, generally 2019 through 2021. The taxpayer must have either already paid the penalty or still have it outstanding on their IRS account. And the taxpayer must be able to demonstrate “reasonable cause” for the late filing or late payment, meaning the failure resulted from circumstances beyond their control rather than willful neglect.
Common scenarios that could support a reasonable cause claim include:
- Serious illness, including COVID-19 itself or caring for a family member who was ill
- Inability to access tax records because offices, businesses, or government agencies were closed
- Reliance on a tax professional who was themselves incapacitated or unable to operate
- Financial hardship directly tied to pandemic job loss or reduced income
The IRS outlines the standards for reasonable-cause penalty relief on its website, though each claim is evaluated individually. There is no blanket guarantee of approval.
To find out whether you were assessed penalties during this period, you can pull an IRS account transcript through the IRS Online Account portal or by calling the IRS directly. Penalties typically appear as separate line items on your transcript, distinct from the underlying tax balance.
How to file and what the IRS requires
The vehicle for claiming a refund is IRS Form 843, titled “Claim for Refund and Request for Abatement.” The form asks for the specific tax periods involved, the type of penalty, the amount, and a written explanation of why the penalty should be removed.
A vague or incomplete submission risks rejection. The IRS Internal Revenue Manual (Section 25.6.1.10.3.2.5) spells out what constitutes a valid protective refund claim: the filing must identify the specific tax years, describe the penalties at issue, and clearly state the legal basis for the refund. A form that omits key details, lacks a signature, or fails to specify which penalties are being contested may not count as a valid claim, even if it arrives before the deadline.
The National Taxpayer Advocate has recommended sending Form 843 by certified mail with a return receipt requested. This creates a verifiable record that the claim was postmarked before July 10, a precaution that could prove critical if the IRS later disputes whether a claim was timely filed. Certified mail costs a few dollars at the post office.
Where you mail the form depends on your state of residence. The IRS instructions for Form 843 list the correct service center address. Sending it to the wrong location could delay processing or, in a worst case, cause the claim to miss the deadline window.
For taxpayers unsure how to complete the form or articulate their reasonable cause argument, the IRS offers free help through its Taxpayer Advocate Service and through Volunteer Income Tax Assistance (VITA) sites, though availability may be limited as the deadline approaches.
Why the paper-only requirement matters
The IRS has expanded electronic filing for most tax documents in recent years, which makes the absence of a digital option for Form 843 all the more conspicuous. Taxpayers accustomed to handling everything online may not realize they need to print, sign, and physically mail a document until it is nearly too late.
That friction is not evenly distributed. People without easy access to a printer or a post office, those who move frequently or lack a stable mailing address, and taxpayers with limited English proficiency all face steeper barriers. Low-income filers, who may have been hit hardest by pandemic-era penalties in the first place, are plausibly the group most likely to miss this deadline entirely.
The National Taxpayer Advocate has publicly urged the IRS to ramp up outreach. As of June 2026, no large-scale public awareness campaign has been announced.
What the IRS has not disclosed
Several practical questions remain unanswered. The IRS has not said how many Form 843 claims tied to COVID-era penalties have been filed so far, nor has it published processing timelines for claims already in the pipeline. Without that information, it is impossible to gauge whether the agency is staffed and prepared for a potential surge of paper filings in the final weeks before July 10.
The enforcement posture around the deadline also lacks clarity. The Taxpayer Advocate’s language says filers “generally” need to submit claims by July 10, leaving open whether narrow exceptions could apply for taxpayers in ongoing disaster areas or those who are incapacitated. No IRS official has publicly stated whether late filings would be categorically denied or reviewed on a case-by-case basis.
The “tens of millions” figure itself is an estimate from the Taxpayer Advocate’s office, not a confirmed IRS count. No breakdown by income level, geography, or penalty type has been released, making it difficult to assess which communities stand to benefit most or which groups face the greatest risk of missing out.
It is also unclear how the IRS will handle claims from taxpayers who are currently in installment agreements or have other open collection activity on their accounts. The Form 843 instructions do not directly address that scenario, and the IRS has not issued public guidance on it.
What to do before July 10
For anyone who struggled through the pandemic and suspects they were penalized for filing or paying late, the steps are straightforward but time-sensitive:
- Check your IRS account. Review your transcripts for any failure-to-file or failure-to-pay penalties assessed for tax years 2019 through 2021. You can do this through the IRS Online Account portal.
- Download Form 843. Get the form and its instructions from the IRS website. Check the instructions for the correct mailing address for your state.
- Write a specific reasonable cause explanation. Describe how the pandemic affected your ability to file or pay on time. Attach supporting documentation if you have it, such as medical records, employer layoff notices, or correspondence showing you could not reach your tax preparer.
- Mail it certified. Send the completed, signed form by certified mail with a return receipt requested. Keep copies of everything you send.
- Do not wait until the last day. The IRS has given no indication it will extend this deadline. Mailing a claim on July 9 leaves zero margin for error.
If the form feels overwhelming, contact the Taxpayer Advocate Service or a local VITA site for free assistance. Paid tax professionals can also help, though fees vary.
A deadline that will not bend
For some taxpayers, the refund at stake could amount to hundreds or thousands of dollars in penalties that were assessed during one of the most chaotic periods in recent American history. The money is real, the legal basis is established, and the IRS has already shown through Notice 2022-36 that it recognizes these penalties were problematic. But none of that matters if the paper does not arrive on time. July 10, 2026, is not a suggestion. For millions of people, it may be the last day the IRS will accept their claim.
