Taxpayers widely assume these refunds will arrive automatically, matching the agency’s 2022 penalty relief program. Official guidance reviewed Tuesday confirms the IRS requires manual paperwork this time, meaning those who simply wait for a check will forfeit their money permanently to the government.
The ruling covers individuals and business owners who paid late filing or payment penalties between January 20, 2020, and July 23, 2023. Tax professionals estimate hundreds of thousands of filers qualify across tax years 2019 through 2022.
Court documents reviewed by this publication show the agency will not proactively notify eligible taxpayers about their specific refund amounts. Citizens must independently request their tax transcripts to verify exact penalty charges before submitting their claims.
$1.2 Billion Precedent Triggers July 10 IRS Application Rush
In California, tax preparers report a massive backlog as 340,000 eligible residents scramble to retrieve historical tax records. Meanwhile, Texas accounting firms indicate nearly 180,000 businesses remain unaware they must initiate the recovery process themselves.
| State | Estimated Eligible Filers | Average Penalty Assessment |
|---|---|---|
| California | 340,000 | $450 |
| Texas | 180,000 | $380 |
| New York | 145,000 | $520 |
Internal budget memos obtained by reporters indicate the agency lacks the dedicated staff to process these manual claims within standard timeframes. Processing divisions face immediate bottlenecks heading into the 2026 tax season.
“Processing these specific forms will require unprecedented agency resources,” National Taxpayer Advocate Erin Collins said.
The manual recovery process requires three distinct steps:
- Download historical account transcripts from the IRS web portal
- Identify specific penalty codes assessed during the COVID-19 national emergency
- Submit a physical copy of Form 843 to the designated processing center
Transcript Backlogs Threaten US Taxpayer Penalty Recovery Efforts
The relief applies specifically to three penalty categories:
- Failure to file penalties
- Failure to pay penalties
- Specific underpayment charges related to pandemic extensions
Taxpayers must submit the paperwork via certified mail, as detailed in official Form 843 instructions. Electronic filing remains unavailable for this specific historical penalty recovery, creating an administrative barrier for those accustomed to digital tax portals.
Some accountants warn the statute of limitations already expired for early 2019 filers. The window legally closes three years after the return was filed or two years after the tax was paid, whichever is later.
The Treasury Department continues to update processing guidelines as the deadline approaches. Taxpayer advocates expect further guidance regarding transcript retrieval delays by mid-April. The agency maintains all claims postmarked after July 10 will face automatic rejection.

