Karson C. Kaebel v. Comm’r, No. 16171-18P, T.C. Memo 2021-109 | September 9, 2021 | Halpern | Dkt. No. 16171-18P

Short Summary:  This case focuses on 26 U.S.C. § 7345, which gives the IRS the authority to recommend to the Secretary of State of the United States that a taxpayer’s passport be denied, revoked, or limited as a result of a seriously delinquent tax debt.  Here, the taxpayer was certified by the IRS pursuant to § 7345 as having such a seriously delinquent tax debt.  The taxpayer argued first that the alleged tax debt was incorrect and second, that § 7345 is unconstitutional.

Key Issues:

• Did the taxpayer have a “seriously delinquent tax debt,” as that term is defined in 26 U.S.C. § 7345;
• Is I.R.C. § 7345 an unconstitutional limitation on a fundamental right? Read More