The Tax Court is weighing whether COVID stopped interest on old tax debt

The Tax Court decided Wepplo v. Commissioner on 2 July, docket 36722-21, covering 2015 through 2017. The taxpayers settled a deficiency case, the court entered its decision on 12 May 2025, and they paid the deficiencies with interest. Within a year they moved under Rule 261 to have the interest redetermined. Their argument is that section 7508A(d), the disaster postponement rule, mandated a period from 20 January 2020 to 10 July 2023 during which interest could not accrue on a tax debt that already existed. The court did not rule. It invited amicus briefs and set oral argument, saying the question appears to affect a potentially very large number of taxpayers. Ed Zollars analysed the order. It is the same statute at issue in Kwong. We could not locate a public copy of the order to link.