Tax Court In Brief | Adams v. Comm'r | "Seriously Delinquent Tax Debt" And Passport Revocation

• Jurisdiction: United States,Federal
• Law Firm: Freeman Law
• Subject Matter: Finance and Banking, Tax, Debt Capital Markets, Income Tax, Tax Authorities
• Author: Freeman Law
• Published date: 09 February 2023

The Tax Court in Brief - January 23rd - January 27th, 2023

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

For a link to our podcast covering the Tax Court in Brief, download here or check out other episodes of The Freeman Law Project.

Tax Litigation: The Week of January 23rd, 2022, through January 27th, 2023

• Lim v. Comm'r, T.C. Memo. 2023-11| January 23, 2023 | Lauber, J. | Dkt. No. 14015-20
• Freman v. Comm'r, T.C. Memo. 2023-10| January 23, 2023 |Jones, J. | Dkt. No. 8895-20
• Shilgevorkyan v. Comm'r, T.C. Memo 2023-12| January 23, 2023 | Ashford, J. | Dkt. No 9247-15
• Belton v. Comm'r, T.C. Memo. 2023-13| January 24, 2023 |Toro, J. | Dkt. No. 22438-19P
• Mulu v. Comm'r, T.C. Summary Opinion 2023-2| January 25, 2023 | Leyden, J. | Dkt. No 12975-21S
• Aragoni v. Comm'r, T.C. Summary Opinion 2023-3| January 25, 2023 | Panuthos, J. | Dkt. No 20914-21S
• Johnson v. Comm'r, 160 T.C. No. 2| January 25, 2023 |Nega, J. | Dkt. No. (Consolidated) 19973-18 19975-18, 19978-18, 20001-18

Adams v. Comm'r, 160 T.C. No. 1| January 24, 2023 | Toro, J. | Dkt. No. 1527-21P

Summary: Petitioner, Blake M. Adams, seeks review pursuant to section 7345(e) of the IRS's certification to the Secretary of State that Adams has a "seriously delinquent tax debt" related to tax years 2007, 2009, 2010, 2011, 2012, 2013, 2014, and 2015 (relevant years).

Adams failed to file federal income tax returns for the relevant years. The IRS prepared a substitute for return for each year. The IRS assessed the tax shown in the substitutes for returns together with penalties and interest. In total, the IRS assessed more than $1.2 million in federal income tax, including interest and penalties. Adams did not pay the assessed amounts. The IRS filed a notice of federal tax lien (NFTL) for each of the relevant years. The IRS notified Adams of the filing of the NFTLs and of his rights, including the right to request a collection due process hearing. Adams did not request a collection due process hearing, and the time to do so lapsed. Thereafter, the IRS certified to the Secretary of State that Adams had a "seriously delinquent tax debt" ($1,206,083.95). Nearly nine months later, Adams petitioned the Tax Court to review the IRS's certification pursuant to section 7345(e)(1). The IRS moved for summary judgment, arguing that Adams had a seriously delinquent tax debt as of the time of the certification and that...