Chill a bowl and beaters (or a whisk attachment for a stand mixer) in the refrigerator for 20 minutes.
Add the heavy whipping cream to the chilled bowl and beat on medium-high speed until frothy and soft peaks form.
Reduce speed to medium and gradually add the confectioners' sugar, lemon juice, and lemon zest while beating. Continue beating until smooth, thick, and stiff peaks form. Use immediately.
