Tax Coda

Tax Coda

IRS passport ban upheld for $1.6M tax debt

Lloyd Thomas Spencer v. Commissioner. U.S. Tax Court. No. 6078-25P.

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Tax Coda
Feb 12, 2026
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The Tax Court upheld the IRS’s certification of a seriously delinquent tax debt, allowing the State Department to deny or restrict the taxpayer’s passport.

Holding

The Court granted summary judgment to the IRS. It sustained the passport certification under §7345 because the taxpayer owed more than $1.6 million in assessed, unpaid, and enforceable trust fu…

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