Notes of Decisions
Maehr v. U.S. Dep't of State, 5 F.4th 1100 (10th Cir. 2021).
“3 22 U.S.C. § 2714a(e)(1), (2). These consequences remain with the taxpayer until any of several circumstances occur, such as full satisfaction of the tax debt, entry into an installment agreement with the IRS, or a finding that the original certification was erroneous.”
Maehr v. U.S. State Dep't, No. 1:18-cv-02948 (D. Colo. Feb. 28, 2020).
· cites it 6× “Contrary to plaintiff’s assertion, 22 U.S.C. § 2714a does not “direct” the Secretary of State to revoke an individual’s passport when certain conditions are met.”
Carmichael v. Pompeo, 486 F. Supp. 3d 360 (D.D.C. 2020).
· cites it 2× “While Government regulations provide the authority to deny passport applications that do not have a social security number, 22 U.S.C. § 2714a(f); see also 22 C.F.R. § 51.”
Quinones, No. 4:25-cv-01202 (E.D. Mo. Mar. 31, 2026).
· cites it 2× “§ 652 (k) and 22 U.S.C. § 2714a(f) as bases for his challenge to the denial of his passport, see Doc.”
Zola Jane Pugh, No. 17992-19 (Tax Ct. Aug. 14, 2023).
“See 22 U.S.C. § 2714a(e) (generally forbidding the State Department from issuing or renewing a passport for a taxpayer certified under section 7345 and authorizing the State Department to revoke a passport previously issued to that taxpayer).”
Maehr v. Internal Revenue Serv., No. 1:22-cv-00830 (D. Colo. Nov. 8, 2022).
“4th at 1105 (citing 22 U.S.C. §§ 2714a(e)(1) and (2) for the proposition that it is the Secretary of State who is prohibited from issuing a new passport or charged with deciding to revoke a previously issued passport on receipt of the certification of a tax delinquency from the…”
Franklin v. United States, No. 3:20-cv-01303 (N.D. Tex. Sept. 29, 2021).
“22 U.S.C. § 2714a(e)(1)–(2). Upon satisfaction of the liability, the statute required the IRS to decertify the debt as promptly as it must release a lien under section 6325 of the Tax Code.”
Jones v. United States Dep't of State, No. 4:25-cv-00130 (N.D. Okla. Mar. 27, 2025).
“22 U.S.C. § 2714a(f)(1)(A). The Secretary’s authority on this point is discretionary: (f) Revocation or denial of passport in case of individual without social security account number (1) Denial (A) In general Except as provided under subparagraph (B), upon receiving an…”
Matthew v. United States, No. 3:25-cv-01664 (S.D. Cal. July 2, 2025).
“” 22 U.S.C. § 2714a. The statute does not require the 12 Secretary to take the action Plaintiff seeks.”
22 U.S.C. § 2714a(2)(A): 1 case
Maehr v. U.S. State Dep't, No. 1:18-cv-02948 (D. Colo. Feb. 28, 2020).
“Contrary to plaintiff’s assertion, 22 U.S.C. § 2714a does not “direct” the Secretary of State to revoke an individual’s passport when certain conditions are met.”
22 U.S.C. § 2714a(e): 1 case
Zola Jane Pugh, No. 17992-19 (Tax Ct. Aug. 14, 2023).
“See 22 U.S.C. § 2714a(e) (generally forbidding the State Department from issuing or renewing a passport for a taxpayer certified under section 7345 and authorizing the State Department to revoke a passport previously issued to that taxpayer).”
22 U.S.C. § 2714a(e)(1): 3 cases
Maehr v. U.S. Dep't of State, 5 F.4th 1100 (10th Cir. 2021).
“3 22 U.S.C. § 2714a(e)(1), (2). These consequences remain with the taxpayer until any of several circumstances occur, such as full satisfaction of the tax debt, entry into an installment agreement with the IRS, or a finding that the original certification was erroneous.”
Maehr v. Internal Revenue Serv., No. 1:22-cv-00830 (D. Colo. Nov. 8, 2022).
“4th at 1105 (citing 22 U.S.C. §§ 2714a(e)(1) and (2) for the proposition that it is the Secretary of State who is prohibited from issuing a new passport or charged with deciding to revoke a previously issued passport on receipt of the certification of a tax delinquency from the…”
Franklin v. United States, No. 3:20-cv-01303 (N.D. Tex. Sept. 29, 2021).
“22 U.S.C. § 2714a(e)(1)–(2). Upon satisfaction of the liability, the statute required the IRS to decertify the debt as promptly as it must release a lien under section 6325 of the Tax Code.”
22 U.S.C. § 2714a(e)(2): 1 case
Maehr v. U.S. State Dep't, No. 1:18-cv-02948 (D. Colo. Feb. 28, 2020).
“Contrary to plaintiff’s assertion, 22 U.S.C. § 2714a does not “direct” the Secretary of State to revoke an individual’s passport when certain conditions are met.”
22 U.S.C. § 2714a(e)(3): 1 case
Maehr v. U.S. State Dep't, No. 1:18-cv-02948 (D. Colo. Feb. 28, 2020).
“Contrary to plaintiff’s assertion, 22 U.S.C. § 2714a does not “direct” the Secretary of State to revoke an individual’s passport when certain conditions are met.”
22 U.S.C. § 2714a(f): 3 cases
Quinones, No. 4:25-cv-01202 (E.D. Mo. Mar. 31, 2026).
“§ 652 (k) and 22 U.S.C. § 2714a(f) as bases for his challenge to the denial of his passport, see Doc.”
Carmichael v. Pompeo, 486 F. Supp. 3d 360 (D.D.C. 2020).
“While Government regulations provide the authority to deny passport applications that do not have a social security number, 22 U.S.C. § 2714a(f); see also 22 C.F.R. § 51.”
22 U.S.C. § 2714a(f)(1): 1 case
Carmichael v. Pompeo, 486 F. Supp. 3d 360 (D.D.C. 2020).
“While Government regulations provide the authority to deny passport applications that do not have a social security number, 22 U.S.C. § 2714a(f); see also 22 C.F.R. § 51.”
22 U.S.C. § 2714a(f)(1)(A): 1 case
Jones v. United States Dep't of State, No. 4:25-cv-00130 (N.D. Okla. Mar. 27, 2025).
“22 U.S.C. § 2714a(f)(1)(A). The Secretary’s authority on this point is discretionary: (f) Revocation or denial of passport in case of individual without social security account number (1) Denial (A) In general Except as provided under subparagraph (B), upon receiving an…”
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