Enforcement desk · Tax attorney Darrin T. Mish

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Enforcement alert

The IRS has more tools than levies and liens.

Passport certification. Refunds swept into old debts. Seizure and public sale. Summonses served on your bank. A private collector on the phone. These are the enforcement tools most people never see coming. Each one runs on specific rules, and each one has a way out.

Five tools, five playbooks

Which one hit you?

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Protocol

The first 72 hours

1

Identify the tool

Read the notice number and the Code section it cites. A CP508C, a CP49, a Form 2433, a Form 2039 and a CP40 each trigger different rules and different clocks.

2

Find the deadline

Some windows are short: 20 days to petition to quash a third-party summons, 10 business days to appeal a seizure, 90 days for the State Department to hold a passport application.

3

Pick the exit

Most of these tools switch off when the account moves into a recognized resolution: an installment agreement, an offer, hardship status, or a pending appeal.

New guides

Latest from the enforcement desk

Passport Certification

What Counts as Seriously Delinquent Tax Debt in 2026?

The number is more than $66,000 for 2026, but the dollar figure is only one of four tests. Here is exactly what the IRS adds up and what it leaves out.

Passport Certification

Passport Certification Exceptions: Who the IRS Cannot Certify

The statute carves out some debts and IRS policy carves out more. If your account fits one of these categories, certification should not happen, and if it already did, it should be reversed.

Passport Certification

Got a CP508C Notice? A Step-by-Step Response Plan

The CP508C is the IRS telling you it has already certified your tax debt to the State Department. It is not a proposal. It is a report of something done, and the response is a plan, not a reply letter.

Passport Certification

How to Reverse a Passport Certification, Including the 9 to 16 Day Expedite

Reversal is a statutory duty, not a favor. Once the account qualifies, the IRS has to tell the State Department, and with proof of travel it can do it in roughly two weeks.

Passport Certification

Challenging a Passport Certification in Tax Court or District Court

Congress gave taxpayers a narrow lawsuit over passport certification. It can fix a wrong certification. It cannot relitigate whether you owe the tax.

Passport Certification

Passport Denial and Revocation: What the State Department Does After IRS Certification

The IRS certifies. The State Department acts. Knowing which agency holds which lever tells you who to call, what to send, and how much time you really have.

Passport Certification

Can Business Tax Debt Cost You Your Passport? TFRP and IRC 7345

Passport certification applies to individuals. That sounds like business owners are safe. They are not, because some business taxes become personal liabilities, and those count.

Refund Offsets

The Treasury Offset Program: Who Can Take Your Federal Tax Refund

Your refund passes through two checkpoints before it reaches you. The IRS takes what you owe in federal tax. Then the Bureau of the Fiscal Service takes what you owe everyone else on the list.

Refund Offsets

Notice CP49: The IRS Used Your Refund to Pay Back Taxes

A CP49 is the IRS showing its work. It took your refund, applied it to a federal tax balance, and is telling you where it went. The job now is to make sure the math is right.

Next step

Got an IRS enforcement notice? Get a lawyer's read on it.

Passport certification, a seized refund, a seizure notice, a summons or a call from a private collector: each one has deadlines and specific exits. Talk to a tax attorney before you respond.