Urgent CPA / EA / Tax Attorney Needed — Must Have Filed Kwong Protective Claims

I need an experienced U.S. tax controversy professional to urgently review IRS filing packets before I mail them. Important: Please do not apply unless you are already familiar with the Kwong v. United States ruling and have personally prepared, reviewed, or filed Kwong-related protective refund or abatement claims. This is a time-sensitive matter involving: * Kwong v. United States * IRS Form 843 protective claims * COVID disaster-period refund / abatement arguments * IRC §7508A(d) * S-corporation late-filing penalties under IRC §6699 * Individual income tax refund statute issues * IRS Letter 105C claim disallowance * Form 1040-X / refund statute / amended return complications I already have draft filing packets prepared. I need a qualified tax professional to review them for accuracy, procedural correctness, wording, form selection, and mailing strategy before I send them by certified mail. Required Experience You must have direct experience with Kwong-related protective claims. Please only apply if you have already done at least one of the following: * Filed a Kwong protective refund claim. * Reviewed a Kwong protective refund claim for a client. * Prepared Form 843 filings based on Kwong / COVID disaster-period deadline arguments. * Advised clients on Kwong, Abdo, IRC §7508A(d), or COVID disaster-period protective refund claims. General tax preparation experience is not enough for this project. I need someone who understands the current Kwong protective-claim issue and the July 10, 2026 filing urgency. Background There are two main categories of filings. 1. Business / S-Corp Protective Claims Entity: Single-shareholder S corporation Return type: Form 1120-S Issue: Late-filing penalties under IRC §6699 and related interest Draft Form 843 protective claim packets have been prepared for: * 2020 * 2021 * 2022 * 2023 These are intended as protective refund / abatement claims based on the reasoning of Kwong v. United States, IRC §7508A(d), and related COVID disaster-period deadline arguments. 2. Personal / Individual Claims There is also a personal 2021 individual income tax matter involving: * Late-filed 2021 Form 1040 * IRS Letter 105C disallowing a refund claim as untimely * A 2021 Form 1040-X that reduced tax based on an S-corporation stock-basis loss * Form 7203 support * IRS offset of a later-year refund against the 2021 balance * Separate Kwong protective claim / reconsideration package I may also need a separate 2020 personal income-tax protective claim reviewed afterward. What I Need Reviewed I need you to review: * Four S-corp Form 843 protective claim packets. * Protective claim statements. * Cover letters. * Personal 2021 protective claim / reconsideration packet. * Calculations and amounts claimed. * Form selection. * Mailing strategy. * Whether the filings should be separated or combined. * Whether any language creates unnecessary risk or admissions. * Whether the filings adequately preserve refund / abatement rights before the July 10, 2026 Kwong-related deadline. Deliverables I am looking for a fast, practical review — not a long academic memo. Please provide: 1. Any urgent corrections before mailing. 2. Confirmation of whether the filings are procedurally reasonable. 3. Recommended wording changes. 4. Any missing forms or attachments. 5. Recommended mailing address / mailing strategy. 6. Whether any claims should be filed as Form 843, Form 1040-X, or separate protective claim letters. 7. Any deadline concerns. 8. Any issue that could cause the IRS to reject or misprocess the claim. Ideal Credentials Preferred: * CPA with tax controversy experience * Enrolled Agent with IRS representation experience * Tax attorney Strong preference for someone who has already handled: * Kwong protective refund claims * Form 843 claims * IRC §6511 refund statute issues * IRC §7508A disaster postponement issues * IRS penalty abatements * S-corporation penalties under IRC §6699 * IRS Appeals or audit reconsideration * Letter 105C disallowances Timeline This is urgent. I need review completed within 24–48 hours, ideally sooner. The goal is to mail everything by certified mail as soon as possible. Confidentiality The documents contain sensitive tax information. Please confirm that you can handle the documents confidentially and securely. I can provide redacted versions first if needed, then full versions after engagement.