Should Kwong protective claims also cite Abdo and PL 119-64 in addition to PL-116-94 (Dec 20, 2019)?

I've been researching filing a protective claim citing Kwong and have come up with a couple other related citations (I think). What does the group say?

Note: In my case I am pursuing a refund, not an abatement, so if you need abatement for penalties due and not yet paid, the language may require some revision.

My current draft (in part):

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This filing constitutes a protective claim for refund pursuant to: Kwong v. United States, 179 Fed. Cl. 382 (Nov. 25, 2025), currently pending appeal; Abdo v. Commissioner, 162 T.C. 148 (2024), a reviewed opinion of the United States Tax Court, now final; IRC §7508A(d) as enacted by P.L. 116-94 (Dec. 20, 2019); and the Disaster Related Extension of Deadlines Act, P.L. 119-64 (Dec. 26, 2025).

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I have more supporting language, that I can include if this post garners attention and if the group deems my approach correct so far. I did not include everything intentionally as I didn't want to risk someone copying and pasting my language should it be deemed incorrect or incomplete.

Why include Abdo: While Abdo does not directly support the refund claim, it contributes the foundational statutory interpretation principle — that §7508A(d) is mandatory and self-executing and cannot be narrowed by Treasury regulation. It was Kwong that took the Abdo framework and applied it broadly to extend the time for filing a refund suit.