Form 843 Sample for Preventive Refund Claim
Fill out Form 843 as best you can, and get it mailed before July 10, 2026
Page 1
At the top of the page, above “Claim for Refund and Request for Abatement,” write “Protective Refund Claim Pursuant to Kwong Case.”
Under “Other,” check the box that says “Other (specify)” then write: “Protective refund claim of penalty and interest due to Kwong.”
Enter name, address, and SSN of taxpayer [and spouse if you filed jointly for the year in question].
Enter the start and end dates for the Tax year in question on Line 1
Enter refund amount on Line 2
Enter the date(s) of payment(s) you made that should be refunded on Line 3
Check box e) Income on Line 4
Page 2
Check box i) 1040 on Line 5
Check box d on Line 7
In box 8, write “This is a protective refund claim due to Kwong v United States, 179 Fed. Cl. 382 (2025)” and “This claim is timely under 6511(a) because the three-year period cannot run during the COVID-19 postponement period; the period therefore ends on July 10, 2026. This claim is filed within that window.”
Sign and date (taxpayer and spouse if joint return).
Enter IP PIN if you/spouse has one for 2026.