Tax Notes Features Jonathan Amitrano on Disaster Deadline Extension Debate

April 14, 2026

Taylor Nelson Amitrano is delighted to share that Managing Partner Jonathan Amitrano was recently quoted in an article published in Tax Notes. The article examines the evolving litigation landscape surrounding the COVID-19 disaster and the mandatory postponement period under I.R.C. § 7508A.  

In recent and future litigation, Courts are interpreting Section 7508A and whether the COVID-19 disaster extended certain tax deadlines to July 10, 2023.  This issue is now surfacing in both civil and criminal tax matters. In United States v. Goldstein, the issue focuses on whether those extensions could affect key elements of certain tax-related charges.

In the article, Jonathan emphasized that where the existence and timing of a legal duty are genuinely in dispute, establishing willfulness in criminal tax cases becomes significantly more difficult.

Taylor Nelson Amitrano values the opportunity to engage in these nuanced, high-stakes discussions shaping tax controversy law.

To learn more about Jonathan’s background and experience in tax controversy law, visit his bio here.