On March 30, 2021, the Tax Court issued its opinion in Rowen v. Commissioner, 156 T.C. No. 8. The underlying issue presented in Rowen v. Commissionerwas whether the IRS’s certification of the petitioner’s tax debt as “seriously delinquent” violated the Fifth Amendment and his basic human rights, because it infringed on his right to international travel. Background to Rowen v. Commissioner For more than two decades the petitioner avoided paying his taxes.  The opinion notes that the petitioner “failed” to pay his Federal taxes, but I believe “avoid” is a bit more indicative of the petitioner’s success in not paying his taxes. In 2018, when the petitioner’s outstanding tax balance was close to $500,000, the IRS “turn to a new tool in its collection toolbox” – IRC § 7345, which permits the IRS to certify that an individual has a “seriously delinquent tax debt.” This certification is then sent to…