Ca. Tax Lawyer MAY 2020, VOLUME 29, NUMBER 1

Comments and Proposed Guidance on the IRS’ Revocation or Denial of Passport in Case of Certain Unpaid Taxes Under Internal Revenue Code Section 73451

By Steven L. Walker and Adria S. Price2


This paper provides comments and recommendations from practitioners with respect to the Service’s implementation of Internal Revenue Code (IRC) Section 73454, revocation or denial of passport in case of certain tax delinquencies.

The authors recognize that the Service must take steps to collect seriously delinquent tax debts and that denying an individual a U.S. passport (or renewal thereof) or revoking any U.S. passport previously issued to an individual can motivate a certain class of taxpayers to take steps to handle their tax compliance issue. However, the authors believe that there are adjustments that the Service could make to the implementation of Section 7345 to make this process less onerous on taxpayers, encourage compliance, and enable taxpayers’ representatives to work within the system and resolve the collection issue prior to a loss of passport rights.

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