IRS and Passport Revocations: Section 7345
Your new client is preparing for a business trip abroad. He was just notified by the IRS that he
has a seriously delinquent tax debt. Client received a “CP508C Notice” that informed him the tax
debt was “certified” to the secretary of state under section 7345.
Prepare a Memo for your client that discusses the operation of section 7345 and how the Notice
that he received will impact his travel plans.
Your memo must also discuss the two (2) recent
U.S. Court of Appeals cases and two (2) U.S. Tax Court decisions that have considered taxpayer
challenges to section 7345 and how those cases resolved access to their passports. You should
also discuss any existing IRS guidance applicable to advising your client. While you can mention
any proposed legislation (or guidance) in your memo, you must advise the client on how the law
actually in impacts the tax and travel aspects of his plans to fly abroad.
Finally, after having discussed the governing law and authorities, what recommendations do you
have for the client about undertaking the travel? For example, should the outstanding taxes be
paid, a collection alternative be proposed, or litigation pursued?
In writing the Memo, you must rely on, and cite, the primary sources. While you can use
secondary sources for background on the issue, your recommendations to the client must be
must be based on the primary authority.
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