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GARCIA v. COMMISSIONER

Docket No. 7612-20P.

157 T.C. 1 (2021)

157 T.C. No. 1

MORRIS F. GARCIA, DECEASED, AND SHARON GARCIA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 19, 2021.

Attorney(s) appearing for the Case

Sharon Garcia, pro se.

Susan K. Bollman and John S. Hitt, for respondent.

OPINION

This passport case is before the Court on a dispositive motion filed by the Internal Revenue Service (IRS or respondent). Section 7345, enacted in 2015, is captioned "Revocation or Denial of Passport in Case of Certain Tax Delinquencies."1 It provides that, if the Commissioner certifies...

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