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