Mattson v. Comm’r, T.C. Memo. 2022-118 | December 6, 2022 |Copeland, J. |Docket No. 16982-18P
Summary: Eric Mattson did not file income tax returns for tax years 2001, 2002, and 2005 through 2008. The IRS prepared substitutes for returns using third-party information return documents. In six separate notices of deficiency the IRS determined various deficiencies and additions to tax for each year in issue. Mattson contested none of them. So, the IRS assessed the deficiencies, additions to tax, and applicable interest. To collect Mr. Mattson’s outstanding tax liabilities for the years in issue, the IRS mailed Mr. Mattson a Notice CP508C, Notice of certification of your seriously delinquent federal tax debt to the State Department (certification notice) that (1) notified Mr. Mattson that his tax debt was $61,933.71 and (2) certified to the State Department that his tax debt is seriously delinquent such that the State Department was prohibited from issuing or renewing a passport to Mr. Mattson. Mr. Mattson filed a Petition with the Tax Court pursuant to section 7345(e)(1), and both the IRS and Mr. Mattson moved for summary judgment on the certification notice issue.
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