The Internal Revenue Service is authorized to certify taxpayers with “seriously delinquent tax debt” (more than $50,000 in unpaid tax assessments, including any assessed interest and penalties) to the State Department for denial or revocation of a passport, under legislation enacted in 2015. See 26 U.S.C. § 7345. A taxpayer may challenge the IRS’s certification (or failure to reverse the certification) in either a district court or Tax Court proceeding. See 26 U.S.C. § 7345(e)(1). The Tax Division will handle all suits filed in district court challenging the IRS’s certification, and the United States Attorney’s Office should immediately notify both the Chief of the appropriate Civil Trial Section and the appropriate IRS counsel on receiving notice of such a suit.

[added February 2018]