On June 25, 2020, the Tax Court issued its opinion in Ruesch v. Commissioner (154 T.C. No. 13). The two issues in Ruesch v. Commissioner were (1) whether the Tax Court possessed jurisdiction under IRC § 7345(b) to consider the petitioner’s challenge to her underlying tax debts; and (2) whether the Tax Court possessed jurisdiction to review the petitioner’s challenge to the IRS’s certification of the petitioner’s liabilities as “seriously delinquent pursuant to IRC § 7345(e). Framework of IRC § 7435 (Denial, Revocation, or Limitation of Passport for Seriously Delinquent Tax Debt) IRC § 7345 (Revocation or Denial of Passport in Case of Certain Tax Delinquencies), enacted in 2015, provides that, if the IRS certifies that an individual has a seriously delinquent tax debt, the IRS may coordinate with the State Department to deny, revoke, or limit the delinquent taxpayer’s passport. IRC § 7345(a). A taxpayer aggrieved by such action…