This may work for an IA or to get small-claimer treatment, but not for a passport grab, as Ch J-elect Patrick J. (“Scholar Pat”) Urda reminds Drew J. Pfirrman, T. C. Memo. 2025-22, filed 3/18/25.

Drew had run up $143K when IRS certified the debt to State, T. C. Memo. 2025-22, at p. 5. Drew claimed he’d paid the debt down below the then-current $59K cutoff for seriously delinquent.

“In addition to questioning his underlying tax liability, Mr. Pfirrman also suggests that he has made payments that have dropped the liability ‘below the threshold of this Court review.’ Mr. Pfirrman misunderstands the statutory structure. 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). Unless a taxpayer satisfies the section 7345(b)(2)(A) exception, a partial payment does not justify reversal of a certification or otherwise end the matter, even if the partial payment drops the amount of the unpaid, assessed, and legally enforceable liability below the… threshold for certification of a seriously delinquent tax debt.” T. C. Memo. 2025-22, at p. 6.

Of course underlying liability is a nonstarter in a passport grab.

Btw, the Section 7345(b)(2)(A) exception covers timely-paid installment agreements, inapplicable here.