I note Judge James S. (“Big Jim”) Halpern’s grant of summary J to IRS in Arelia Margarita Taveras, Docket No. 9233-25, filed 4/14/26, for want of anything better coming out of The Glasshouse in the City At War. I’m truly sorry for the petitioner, who threw away a worthwhile career for a compulsion. She does put up a fight, but only two (count ’em, two) of her seven (count ’em, seven) objections to IRS’ summary J motion survive the Ruesch/Garcia jurisdictional limit for passport grabs. And she loses those two.
Strange that the docket number doesn’t add the “P” for Section 7345s.
Arelia is thorough, but the barrier remains. Is there an assessment of a seriously delinquent tax debt? Yes. Validity thereof is to be tested in deficiency or CDP litigation, not passport grabs. She had her chances.
It’s a shame Arelia can no longer exercise her considerable abilities in her chosen profession.
Taishoff Law 
But the statute expires on May 23? Maybe that explains the rush. Does she get her passport back next month?
And the order ends with a reference to “respondent’s certifications that petitioners have seriously delinquent tax debt.” Cut and paste from an earlier decision involving a joint return? Only one petitioner in this case.
And yes, the Clerk should have been ordered to append a P.
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As for receiving her passport back, see Section 7345(c)(2). Expiry of SOL is not a ground for reversal.
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