How to Read Your IRS Account Transcript for COVID-Era Penalties (A Step-by-Step Guide)

In one paragraph

The IRS account transcript shows every penalty, interest charge, and assessment posted to a taxpayer's account, identified by three-digit transaction codes (TCs) and dated. To check whether COVID-era penalties may be refundable under Kwong v. United States: pull an Account Transcript from IRS Get Transcript, find penalty TCs (166, 170, 270, 276, 196), and cross-reference the assessment dates against the COVID disaster window of January 20, 2020 – July 10, 2023. Penalties whose underlying due dates fell inside that window may be claimable on Form 843 before July 10, 2026.

Step 1 — Request your IRS account transcript

The IRS offers four transcript types: Tax Return Transcript, Tax Account Transcript (also called Account Transcript), Record of Account Transcript, and Wage and Income Transcript. For penalty-refund analysis you specifically need the Account Transcript.

• Online (fastest): Sign in at IRS Get Transcript. Identity verification is required. Once verified, request "Account Transcript" for each year you want to review.
• By mail: File Form 4506-T. Mailed transcripts arrive in 5–10 business days.

Pull transcripts for every tax year that may have COVID-era penalties — typically 2019, 2020, 2021, 2022, and possibly 2023.

Step 2 — Identify the right section of the transcript

The Account Transcript has a header (showing taxpayer ID, filing status, account balance) and a body listing every transaction in chronological order. Each transaction has:

• Transaction Code (TC): three-digit code identifying the type
• Date: when the transaction was posted (NOT necessarily the underlying event date)
• Amount: dollar amount, debits positive, credits negative

Step 3 — Find the penalty transaction codes

Step 4 — Cross-reference with the COVID disaster window

The COVID-19 federally declared disaster ran from January 20, 2020 through July 10, 2023. For each penalty, the question is whether the underlying due date — not the transcript posting date — fell inside that window.

• 2019 individual return: due April 15, 2020 — inside the window
• 2022 individual return: due April 18, 2023 — inside the window
• 2023 individual return: due April 15, 2024 — outside the window
• 2018 return filed late in 2021: original due date April 15, 2019 — outside the window

Step 5 — Calculate the dollar amount per year

1. List every penalty TC on the transcript for years inside the window.
2. For each, write down the dollar amount.
3. Subtract any matching abatement TCs (167/271/277) for the same penalty.
4. The remainder is the net penalty the taxpayer actually paid.
5. Sum the remainders across all in-window years to get the total potential refund amount.

Worked example: a 2020 return originally due April 15, 2021 has TC 166 (FTF) for $1,200, TC 270 (FTP) for $400, and TC 196 (interest) for $200 — total $1,800 in COVID-era assessments. If the taxpayer received a $300 abatement under Notice 2022-36 (TC 167), the net is $1,500. That $1,500 is the potential Kwong-based refund amount for that year.

Step 6 — Decide between a refund claim and a protective claim

Both are filed on Form 843. The difference is the wording at the top and the explanation in line 7.

• A refund claim assumes Kwong is good law as of filing.
• A protective claim preserves the right to a refund while the appeal is pending. Header: "Protective Refund Claim Pursuant to Kwong Case".

Step 7 — File one Form 843 per year, mail certified

Form 843 must be printed and mailed on paper. The IRS does not currently accept Form 843 electronically.

• One Form 843 per tax year.
• Mail certified with return receipt. Establishes the filing date for the § 6511 deadline.
• Keep copies of everything.
• Allow 6–9 months for IRS response.

Frequently asked questions

Can I get the transcript for someone else (family member or business)?

For a family member: only with Form 2848 or 8821 on file. For a business: an officer with authority can request directly.

What if my transcript shows a transaction code I do not see in your table?

For COVID-era penalty analysis, codes 166, 167, 170, 171, 196, 197, 240, 241, 270, 271, 276, 277 are the ones that matter. Other codes are typically not penalties.

What if the IRS already abated my penalties under Notice 2022-36?

You may still be eligible for additional refunds outside the narrow scope of Notice 2022-36 — the Kwong reading is broader.

The transcript posting date is different from the return due date. Which one matters?

The underlying due date matters — the original due date of the return.

What if my year is partially in and partially out of the window?

Estimated-tax installments are evaluated independently. The original return due date typically falls inside or outside as a single date.

Do I need a tax professional to read my transcript?

No, but PenaltyBack's free check pulls and analyzes the transcript automatically.

How long does a Form 843 claim usually take?

Practitioner experience suggests 6–9 months. The taxpayer's filing date is what matters for the § 6511 deadline.