A taxpayer cannot use a passport revocation case to dispute the underlying tax liability once the IRS has properly assessed the debt and followed the statutory collection steps.
Holding
The Tax Court held that the IRS properly certified Kavan Shaban as having a “seriously delinquent tax debt” under §7345 and rejected his challenge to that certification.
Why It Matters
Routine application of §7345 passport rules. The Court again confirmed that passport certification cases are narrow proceedings focused only on whether statutory certification requirements were met.
Underlying liability cannot be relitigated. Even compelling facts, including embezzlement by a business partner, do not allow taxpayers to contest the tax liability itself in a passport case.
Procedural deadlines matter. Failure to request a collection due process hearing after lien and levy notices removes later opportunities to challenge the liability.
Automation does not invalidate certification. IRS computer systems may identify…
