[Date]
Internal Revenue Service
[Address shown at the top of Notice CP508C]
[Or: faxed to or uploaded for the ACS or Field Collection employee assigned to the account, name and ID number]
Re: Request for reversal of certification of seriously delinquent tax debt under IRC 7345(c) [and request for EXPEDITED decertification (travel on [date]). Delete if not expedited.]
Taxpayer: [Client legal name] SSN: [SSN]
Notice CP508C dated: [Date] (copy enclosed) Certified modules: [Form and tax periods listed on the CP508C; include any BMF TIN shown]
Daytime telephone: [Client phone] Representative: [Name and phone] (Form 2848 enclosed)
To whom it may concern:
I represent the taxpayer named above under the enclosed Form 2848. The taxpayer was certified to the Department of State as owing a seriously delinquent tax debt by Notice CP508C dated [Date]. The taxpayer requests that the IRS reverse the certification, notify the Department of State, and issue Notice CP508R, for the reason checked below.
1. Ground for reversal
[Keep the paragraph that applies and delete the others.]
(a) The debt is fully satisfied or legally unenforceable (IRC 7345(c)(1)). The certified modules were paid in full on [Date(s) and amounts; EFTPS or bank confirmation enclosed] [or: the collection statute for [periods] expired on [date] / the liability was discharged in bankruptcy case no. [number] on [date]]. The account transcript enclosed shows [status 12 / zero balance / TC 608] for each certified module.
(b) The debt is no longer seriously delinquent because a statutory exclusion under IRC 7345(b)(2) applies. [Choose one: An installment agreement under IRC 6159 was approved on [date] (acceptance letter or Form 433-D enclosed) and payments have been made on [dates]; the transcript shows TC 971 AC 063 posted [date]. / An offer in compromise was accepted on [date] (acceptance letter enclosed; TC 780). / A timely CDP hearing request under IRC 6330 was filed on [date] in response to [LT11 / Letter 1058] dated [date] for the certified periods (Form 12153 and proof of mailing enclosed; TC 971 AC 275 or TC 520 cc 76/77). / A request for innocent spouse relief under IRC 6015 was filed on [date] for the certified periods (Form 8857 and proof of mailing enclosed; TC 971 AC 065). / The taxpayer has served in a combat zone since [date] (orders enclosed).] Under IRC 7345(c)(2) the notification to the Department of State is due within 30 days after an installment agreement is entered into, an offer is accepted or an innocent spouse request is made.
(c) The debt is no longer seriously delinquent because a discretionary exclusion in IRM 5.19.25.5 applies. [Choose one: The account was placed in currently not collectible status due to hardship on [date] (TC 530 cc 24 to 32). / The taxpayer filed bankruptcy on [date], case no. [number] (TC 520). / The IRS determined on [date] that the liability for [period] resulted from identity theft (TC 971 AC 522/525). / The taxpayer's address is in a federally declared disaster area covered by [IRS news release] (TC 971 AC 87). / An installment agreement was requested on [date] and is pending (TC 971 AC 043). / An offer in compromise was submitted on [date] and is pending (TC 480). / An adjustment that will fully pay the period is pending: [describe; TC 470 cc 90].]
(d) The certification was erroneous. [State why the debt did not meet IRC 7345(b)(1) on the date of certification or why an exclusion already applied, for example: a timely CDP levy hearing request was filed on [date], before certification, but was not coded on the account; the installment agreement approved on [date] was not coded TC 971 AC 063; the aggregate assessed balance on the certification date was $[amount], below the $66,000 threshold for 2026; no notice of federal tax lien had been filed and no levy had been made for the certified periods; the certified periods include a liability that is not a tax debt within IRC 7345 (describe).] Under IRC 7345(c)(2)(D), notification of an erroneous certification is to be made as soon as practicable after the finding.
2. Status of the account
All certified modules are listed above. [No other module is certified / The following modules are also certified and are resolved as follows: [list].] The taxpayer is in compliance with filing requirements for [years]. Enclosed account transcripts dated [Date] show the transaction codes cited above. [If the codes are posted but the reversal has not: The exclusion posted on [date], more than 30 days ago, and no TC 972 AC 641 appears on the module. I ask that the account be referred to the SB/SE passport group for review of the certification.]
3. Expedited decertification (IRM 5.19.25.10.1)
[Delete this section if travel is not within 45 days.] The taxpayer is scheduled to travel internationally on [Date, within 45 days] to [Destination]. Enclosed are:
- Proof of travel: [flight itinerary / hotel reservation / cruise ticket / international car insurance] showing the taxpayer’s name, the location and the travel date;
- A copy of the Department of State letter dated [Date, within the past 90 days] denying the taxpayer’s passport application or revoking the passport, showing passport application number [Number from the State Department letter];
- Proof that the taxpayer is eligible for decertification as stated in section 1, with the posting date of the exclusion: [Code and date].
[If the taxpayer lives outside the United States: The taxpayer resides at [foreign address] and has an urgent need for a passport because [reason]. The taxpayer meets the exclusion in section 1. Under IRM 5.19.25.10.1, proof of travel and a Department of State denial letter are not required for a taxpayer residing outside the United States; the location of the application request is [post or agency].]
The taxpayer asks that Form 14794, Expedited Passport Decertification, be completed and forwarded to the SB/SE passport group with the travel date in the subject line. [For a joint liability where both spouses need a passport: A separate request for [spouse name, SSN] is enclosed.] No revocation referral (TC 971 AC 644) appears on the account.
4. Request
Please reverse the certification for all modules listed above, notify the Department of State, and send Notice CP508R to the taxpayer and a copy of any correspondence to the representative. If any item is missing from this request, please call me at the number below before closing it. The taxpayer reserves the right to bring a civil action under IRC 7345(e) if the certification is not reversed.
Sincerely,
[Representative name, credential]
[Firm, address, phone, fax, email]
CAF [CAF number]
Enclosures: Form 2848; Notice CP508C; account transcripts for each certified module; [IA acceptance letter or Form 433-D / OIC acceptance letter / Form 12153 and proof of mailing / Form 8857 and proof of mailing / proof of payment / bankruptcy notice]; [proof of travel and Department of State letter, if expedited].
When a letter helps
Reversal is systemic. IRM 5.19.25.10 says the IRS “will systemically notify the DOS within 30 days” when a certified debt is paid, unenforceable or no longer seriously delinquent, and each module reverses with TC 972 AC 641. In most cases the work is getting the installment agreement, offer, CDP request or CNC determination coded, not writing a letter. See passport certification.
The letter earns its place when the exclusion has posted but the module has not reversed (the IRM tells the employee to “request assistance by encrypted email to *SBSE Passport Group with the subject heading Review of Certification”), when the certification was wrong when made (reversed “as soon as practicable”), when the client travels within 45 days and needs an employee to complete Form 14794, or when the client paid: “If you’ve already paid the tax debt, please send proof of that payment to the IRS address at the top of your notice.”
Two limits. “Certifications will not be reversed because the taxpayer pays the debt to below the threshold amount indexed for inflation effective at the time of certification.” And there is no appeal to attach the letter to: “There is no administrative appeal, claim process, or administrative hearing that can be filed with the IRS if the taxpayer believes that a certification is erroneous” (IRM 5.19.25.13).
The grounds for reversal
Section 1 of the letter tracks IRC 7345(c)(1): reversal when the certification “is found to be erroneous or if the debt with respect to such certification is fully satisfied or ceases to be a seriously delinquent tax debt by reason of subsection (b)(2).” The IRM adds discretionary exclusions and applies them uniformly: “A discretionary exclusion does not mean IRS employees have discretion in applying exclusions.” Name the code the employee will look for.
| Ground | IDRS proof | Timing (IRC 7345(c)(2); IRM 5.19.25.10) |
|---|---|---|
| Paid or unenforceable | Status 12 on every certified module; CSED or discharge | By the lien release date under IRC 6325(a) |
| Installment agreement paid timely | TC 971 AC 063 (a short-term plan, TC 971 AC 899, does not qualify) | 30 days after the agreement is entered into |
| Accepted offer in compromise | TC 780 | 30 days after acceptance |
| Timely CDP levy hearing | TC 520 cc 76/77 or TC 971 AC 275; not an equivalent hearing | Systemic, within 30 days |
| Innocent spouse election or request | TC 971 AC 065 | 30 days after the request |
| Discretionary: CNC hardship, bankruptcy, identity theft, pending IA or OIC, pending full-pay adjustment, disaster area | TC 530 cc 24-32; TC 520; TC 971 AC 522/525; TC 971 AC 043; TC 480; TC 470 cc 90; TC 971 AC 87 | Systemic, within 30 days |
| Erroneous certification | IRM examples: IA, CDP request or innocent spouse claim not coded; combat zone not recorded | As soon as practicable |
Match the periods to the CP508C: “Certification will not be reversed where a taxpayer requests a CDP hearing or innocent spouse relief for tax periods which are not the basis of the certification.” Section 4 asks for copies to the representative because “The IRS will not send a copy of the CP508C notice to a taxpayer’s power of attorney.”
The expedited package
IRM 5.19.25.10.1 allows expedited decertification for a domestic taxpayer only when eligibility is confirmed on IDRS, foreign travel is “scheduled within 45 days or less” with proof, and a State Department denial or revocation letter was “issued within the past 90 days.” Section 3 of the letter uses the IRM’s list: “Proof of travel can be a flight itinerary, hotel reservation, cruise ticket, international car insurance, or other document verifying name of taxpayer, location, and date of travel.” The State Department letter carries the item that cannot be omitted: “The passport application number will be on the DOS denial letter. This information must be entered when completing Form 14794, Expedited Passport Decertification, or it is not processable.” The IRS employee, not the representative, completes Form 14794, one per spouse. “Expedited decertification will generally allow for decertification within 9-16 days.” Taxpayers abroad are treated differently: “They do not need proof of travel or a proof of passport denial letter issued by the DOS,” but must state an urgent need and the location of the application. A revocation referral (TC 971 AC 644) bars expedited handling.
Where to send it and what happens next
- Call first if time is short. IRM 5.19.25.12 centralizes passport calls in Philadelphia: 855-519-4965 domestic and 267-941-1004 international. The employee can resolve the account under normal procedures and, for imminent travel, start Form 14794 while you send the documents.
- Send the letter to the address at the top of the CP508C, or to the assigned revenue officer or ACS employee. “Passport certification correspondence will be centralized in Philadelphia.” The IRS page suggests the Document Upload Tool for proof of payment where available.
- If the ground is a collection alternative not yet in place, the request is the installment agreement, offer or CNC request itself; reversal follows the code.
- Watch for TC 972 AC 641 on each module; the last one shows “FINAL” and generates the CP508R. Watch the State Department clock separately: its letter holds the application open for 90 days, after which a new application is needed.
If the IRS does not reverse
IRC 7345(e)(1) allows a civil action in a district court or the Tax Court “to determine whether the certification was erroneous or whether the Commissioner has failed to reverse the certification”; no administrative claim is required first, and the court cannot release a lien or levy or award damages. Ruesch v. Commissioner, 154 T.C. 289 (2020), aff'd in part and vacated in part, 25 F.4th 67 (2d Cir. 2022), held that “section 7345(e) limits our jurisdiction to determining whether the Commissioner erred in certifying (or in failing to reverse a certification) that a taxpayer owes a ‘seriously delinquent tax debt’ as defined in section 7345(b),” so the liability itself is not reviewable, and dismissed the claim as moot once the IRS reversed. Rowen v. Commissioner, 156 T.C. 101 (2021), rejected a right-to-travel challenge; Adams v. Commissioner, 160 T.C. No. 1 (2023), read IRC 7345(b)(1)(A) to require only that the liability “has been assessed.” A petition is for the elements of the certification and the failure to reverse, which sections 1 and 2 of the letter document. See Tax Court petitions.
Mistakes
- Sending the CP508C as the State Department letter. The IRM says the DOS letter “is not referring to the CP 508C”; without it and its application number the request is not processable.
- Relying on a short-term plan or an equivalent hearing. Short-term plans “are not IAs and do not meet the criteria for this exclusion,” and only a timely CDP levy hearing counts; see CDP hearings.
- Promising a passport. “A request for an expedited decertification does not guarantee that the DOS will issue the passport.” The letter asks only for reversal and notification.
Questions practitioners ask
How fast must the IRS act once the installment agreement is approved?
IRC 7345(c)(2)(C) requires notification not later than 30 days after the agreement is entered into or the offer is accepted. Expedited handling shortens the IRS side to about three business days for a processable Form 14794.
Can the representative file Form 14794?
No. The IRS employee completes Part 1, obtains managerial approval and emails it to the passport group. The representative supplies the proof of travel, the State Department letter and the evidence of the exclusion.
Should the letter argue that the tax is not owed?
No. Ruesch holds the liability is not reviewable in a passport case, and the IRS has no administrative process for the certification itself. Contest the liability through audit reconsideration, a CDP hearing or a refund claim; an adjustment that reduces the certified amount below the threshold supports reversal once it posts.