IRS Notice Guide

CP508C Notice: What IRS Passport Certification Means

By Ray Neu, Publisher | Last reviewed: October 26, 2026 | Reading time: 8 min

Short answer

A CP508C is the IRS notice that it has certified a seriously delinquent tax debt to the State Department under 26 U.S.C. § 7345. For 2026 that means more than $66,000 assessed and unpaid, plus either a filed lien with hearing rights used up or lapsed, or a levy. The State Department may then deny or revoke a passport.

This guide draws on § 7345, the IRS passport, CP508C and CP508R pages, and IRM 5.19.25, the Passport Program chapter of the Internal Revenue Manual.

Deadline to know: When a certified taxpayer applies for or renews a passport, the IRS passport page says the State Department holds the application open for 90 days from its letter. If satisfactory payment arrangements are not made with the IRS within that time, the page says the application is denied and closed, and a new one is needed.

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What certification means

Section 7345(a) has the Treasury pass the Commissioner’s certification to the Secretary of State “for action with respect to denial, revocation, or limitation of a passport” under section 32101 of the FAST Act. The CP508C is how the taxpayer learns of it. In the words of the CP508C page, the IRS “has notified the U.S. Department of State,” a passport “may be revoked,” and a new application or renewal “will be denied.”

The IRS mails the CP508C by regular mail to the last known address, and the passport page says it “will not send a copy of the CP508C notice to a taxpayer’s power of attorney.” Earlier notices mention the rule: the IRS page for the CP504 notice says it “also explains the denial or revocation of a United States passport.”

The State Department decides

IRM 5.19.25.2 says the State Department “has the sole authority” to deny, revoke or limit a passport. The IRS can ask it to revoke one, but first sends Letter 6152, which IRM 5.19.25.11.2 says allows 30 days to contact the IRS (90 days if mailed outside the U.S.). A passport already in hand can still be used until the State Department gives written notice, according to the CP508C page, although IRM 5.19.25.2 says revocation can come “without additional advance notice.” Abroad, the passport page says the State Department may issue a limited-validity passport for a direct return to the United States.

The 2026 threshold and the two conditions

The statute’s figure is “greater than $50,000,” indexed for inflation each year under § 7345(f) and rounded to the nearest $1,000. For 2026, the IRS passport page puts the threshold at more than $66,000 of legally enforceable, unpaid federal tax, counting assessed penalties and interest. IRM 5.19.25.3 adds that the total uses assessed amounts and “does not include accrued interest and penalty.”

The amount alone does not trigger certification. Under § 7345(b)(1) the debt must be assessed and meet one of two conditions:

A filed lien with rights used up. A Notice of Federal Tax Lien filed under § 6323, with the § 6320 hearing rights exhausted or lapsed. IRM 5.19.25.3 says a timely or pending lien hearing keeps those rights open until it and any appeal end, but an equivalent hearing does not. The lien filing is explained in the Form 668(Y) guide.
A levy under § 6331. IRM 5.19.25.6 says a levy on a state income tax refund “will not be recognized as a levy until CDP notification is provided.”

Covered debts include individual income taxes, trust fund recovery penalties and other civil penalties; child support and FBAR penalties are not, per the passport page.

Debts the IRS does not certify

Some exclusions are written into § 7345(b)(2). Others are IRS policy, which IRM 5.19.25.5 calls discretionary exclusions and says “are subject to change in the future.” The IRS pages do not list them identically, so the table combines them.

Excluded debt	Where the rule comes from
Paid on time under a § 6159 installment agreement	Statute, § 7345(b)(2)(A)
Paid on time under an accepted § 7122 offer in compromise or a Justice Department settlement	Statute, § 7345(b)(2)(A)
Collection suspended for a requested or pending § 6330 levy hearing	Statute, § 7345(b)(2)(B)
Collection suspended for a § 6015 innocent spouse election or request	Statute, § 7345(b)(2)(B)
Currently not collectible due to hardship	IRS policy, IRM 5.19.25.5
Pending installment agreement or pending offer in compromise	IRS policy, IRM 5.19.25.5
Bankruptcy, or debt from tax-related identity theft	IRS policy, IRM 5.19.25.5
Taxpayer in a federally declared disaster area	IRS policy, IRM 5.19.25.5
Pending adjustment that will fully pay the debt	IRS policy, IRM 5.19.25.5
Deceased taxpayer (on a joint account, only the deceased spouse)	IRS policy, IRM 5.19.25.5 and the CP508R page
Service in a combat zone or contingency operation	Certification postponed, § 7508(a)(3)

IRM 5.19.25.4 notes that short-term payment plans “are not IAs” and do not meet the installment agreement exclusion.

Questions about a CP508C?

An attorney can review whether the debt meets the statute’s conditions and which reversal or court routes apply to the facts.

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The State Department’s 90-day hold

The IRS passport page says that when a certified taxpayer applies for or renews a passport, the State Department sends a letter and keeps the application open 90 days. The window allows a satisfactory payment arrangement, full payment, or a fix for an erroneous certification. Without one of them, the application “will be denied and closed,” and the taxpayer must file a new application.

IRS sources describe that letter both as a hold letter and as a denial letter. The passport page uses both terms, and IRM 5.19.25.10.1 says the application “only stays open for 90 days after the U.S Department of State issues the denial letter.” The State Department’s own page could not be retrieved for this review.

How reversal works: Notice CP508R

The IRS reverses a certification when the debt is fully satisfied or becomes legally unenforceable, is no longer seriously delinquent, or was certified in error, and it then sends Notice CP508R. The CP508R page says no reply is needed and the notice should be kept in permanent records. It also says the State Department can still deny or revoke a passport “for reasons unrelated to your tax debt.”

Timing

The passport page says the IRS reverses and notifies the State Department “within 30 days of resolving the debt.” The statute sets separate outer limits in § 7345(c)(2): the § 6325(a) lien release date, which is 30 days, for a debt that is paid or unenforceable; 30 days after an innocent spouse election or request; 30 days after an installment agreement is entered into or an offer is accepted; and “as soon as practicable” after a certification is found to be erroneous.

What does not reverse it, per the passport page

Partial payments or expiring collection statutes that bring the balance under the threshold.
A CDP hearing or innocent spouse request on a tax period that is not certified.
Resolving only some periods: “the taxpayer must fully resolve all certified tax debt.”

For a taxpayer unable to pay in full, the passport page names an installment agreement or an offer in compromise as routes to reversal. The installment agreement guide covers plan types and limits. A current-year refund large enough to cover the certified debt also counts once the return and refund are processed.

Expedited reversal for travel

The passport page describes a faster route for taxpayers with an open or pending passport application and international travel within the next 45 days, or who live abroad. When expedited, the IRS “can generally shorten the standard 30-day processing time for decertification to 9-16 days.” The request needs:

A reversal condition already met. IRM 5.19.25.10.1 requires the account to be eligible for decertification, for example an installment agreement already recorded.
Proof of travel. A flight itinerary, hotel reservation, cruise ticket, international car insurance or another document showing the traveler’s name, the location and the approximate date.
The State Department letter. A copy of the letter denying the application or revoking the passport, dated within the last 90 days.

IRM 5.19.25.10.1 adds that taxpayers living outside the United States need neither the travel proof nor the denial letter, that a taxpayer whose passport the IRS has already referred for revocation does not qualify, and that the State Department still decides whether to issue the passport. The passport page lists 855-519-4965 and, for international callers, 267-941-1004 as the CP508C numbers.

The right to sue under § 7345(e)

Once notified, a taxpayer may bring a civil action against the United States in a U.S. district court, or against the Commissioner in the Tax Court, to decide whether the certification was erroneous or whether the IRS failed to reverse it. Under § 7345(e)(1), “the court first acquiring jurisdiction over such an action shall have sole jurisdiction.” If the court finds an error, it may order the Treasury to tell the State Department.

The passport page says no administrative claim is required first, and that the court cannot release a lien or levy or award money damages in this kind of case. IRM 5.19.25.13 says there is no administrative appeal of a certification and that it is not a Collection Appeals Program action.

Filing in the Tax Court

Tax Court Rule 351 calls the filing a “Petition for Certification or Failure to Reverse Certification Action Under Code Section 7345(e)” and requires a copy of the certification notice to be attached. As of October 2026 the filing fee is $60, which the Court may waive on a showing of inability to pay.

When an attorney matters

The CP508C page says a taxpayer can authorize a representative, using Form 2848. Publication 594 lists an attorney, a CPA, an enrolled agent, an immediate family member, or anyone enrolled to practice before the IRS as possible representatives in collection. The passport page adds that the IRS does not send a representative a copy of the CP508C. The roles differ in a few places:

Tax Court. The Court says a representative “must be admitted to practice before the Tax Court.” Attorneys apply for admission; nonattorneys qualify through the Court’s examination. A taxpayer may also file without one.
Privilege. Section 7525 lets federally authorized tax practitioners claim attorney-style confidentiality only in noncriminal tax matters.

The attorney vs CPA vs enrolled agent comparison covers the roles in more depth.

Related guides

Frequently Asked Questions

Does a CP508C cancel my passport?

Not by itself. The State Department makes the passport decision. The CP508C page says an existing passport can still be used until the State Department gives written notice, although IRM 5.19.25.2 says revocation can come without additional advance notice. A new application or renewal is generally denied while the certification stands.

What is the 2026 threshold for passport certification?

The IRS passport page sets it at more than $66,000 for 2026, counting legally enforceable, unpaid federal tax including assessed penalties and interest. The statute’s base figure is $50,000, adjusted each year for inflation.

Will paying the balance below the threshold reverse the certification?

No, according to the IRS passport page and IRM 5.19.25.3. Reversal requires full satisfaction, legal unenforceability, an exclusion such as a timely paid installment agreement, or a finding that the certification was erroneous.

Can I appeal a CP508C?

IRM 5.19.25.13 says there is no IRS administrative appeal of a certification, and it is not a Collection Appeals Program action. Section 7345(e) allows a civil action in the Tax Court or a U.S. district court to decide whether the certification was erroneous or should have been reversed.

Talk through a CP508C

A free, confidential evaluation can help sort out the payment, reversal and court options the law makes available.

Start Your Free Evaluation Call (202) 968-1121

About the Author

Ray Neu

Ray Neu is the publisher of IRSAttorneys.net. A former law enforcement officer with a background in criminal justice and digital publishing, he oversees editorial direction, partnership standards, and compliance review for the site. He is not an attorney and does not provide legal advice; all tax law content is sourced and reviewed against the standards documented on the Editorial Team & Standards page.

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IRS Circular 230 Disclosure: To ensure compliance with Treasury Department rules governing tax practice, any tax information contained on this website was not written and is not intended to be used, and cannot be used, for the purpose of avoiding any federal tax penalty. You should consult a licensed tax professional regarding your individual situation.

Results described on this website are not a guarantee, warranty, or prediction of the outcome of any tax matter. Every situation is different. Prior results do not guarantee a similar outcome. Article content reflects general information about federal tax procedure as of the last reviewed date and may not reflect subsequent changes in IRS policy, regulations, or case law.