Did you know that owing the IRS can put your passport at risk? That’s exactly what happened to Drew Pfirrman, a Florida resident who recently lost his Tax Court case after the IRS certified his “seriously delinquent tax debt.”
What Happened?
· Unreported Income: The IRS found Pfirrman had over $367,000 in unreported income for 2018 and hit him with a six-figure tax bill, penalties, and interest.
· IRS Notices Ignored: He missed his chance to challenge the debt through the proper IRS channels.
· Passport in Jeopardy: When his tax debt grew to over $182,000, the IRS notified the State Department, threatening his passport.
Can You Fight It?
Pfirrman tried to argue that his debt was lower and that partial payments should help. But the Tax Court ruled it can’t reconsider the original tax bill in a passport case. Only full payment of the debt (or qualifying for a special exception) can get your passport privileges restored.
The Lesson
Don’t ignore IRS notices. If you owe big, act fast-set up a payment plan or pay in full. Once the IRS certifies your debt, it’s too late to argue about the amount in court, and your travel plans could be grounded.
See also our post TC Determines That Taxpayer's Debt Was 'Seriously Delinquent' Even after He Paid Tax to Reduce Balance below $50,000 where we discussed that once a certification of a seriously delinquent tax debt has been made, it may be reversed "if the debt with respect to such certification is fully satisfied." I.R.C§ 7345(c)(1) (emphasis added).
References
2. https://www.thetaxadviser.com/issues/2025/mar/certification-of-seriously-delinquent-tax-debt-not-erroneous/
3. https://www.leagle.com/decision/intco20250318g64
4. https://www.irs.gov/pub/irs-access/p5827_accessible.pdf
5. https://www.irs.gov/businesses/small-businesses-self-employed/revocation-or-denial-of-passport-in-cases-of-certain-unpaid-taxes
Read more at: Tax Times blog