Potentially dangerous taxpayer

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Potentially Dangerous Taxpayer (PDT)[1] is a government designation assigned by the Internal Revenue Service (IRS) to taxpayers of the United States of America whom IRS officials claim have demonstrated a capacity for violence against employees of the IRS or other government agencies, contractors or their families.[2][3] Suspected PDT cases are handled by the Treasury Inspector General for Tax Administration.[2]


The IRS has established the following criteria for assessing a taxpayer as a PDT, any one of which is sufficient for declaring a taxpayer a PDT:

  1. Taxpayers who have committed acts of violence against IRS employees, contractors and/or their families;
  2. Taxpayers who threaten or intimidate IRS employees, contractors and/or members of their family by threats of bodily harm or other intrinsically threatening behavior, such as stalking;
  3. Taxpayers who are actively involved in groups which promote violence against IRS or other government employees;
  4. Taxpayers who have in fact committed acts of violence or intimidation against employees or contractors of other federal, state, county or local government organization; or
  5. Taxpayers who have demonstrated a capacity for violence by commission of any of the aforementioned acts of violence in the previous five years.[3]

The Internal Revenue Service also designates certain taxpayers as "Caution Upon Contact" taxpayers, or "CAU" taxpayers.[4] The guidelines for the CAU designation are:

  1. Threat of physical harm that is less severe or immediate than necessary to satisfy PDT [potentially dangerous taxpayer] criteria;
  2. Suicide threat by the taxpayer; or
  3. Filing or threatening to file a frivolous lien or a frivolous criminal or civil legal action against an IRS employee or contractor or an IRS employee's or contractor's immediate family member.[5]


In response to an inquiry after the February 18, 2010, suicidal attack on an office of the IRS at Austin, Texas, by Andrew Joseph Stack that resulted in the death of Stack and an IRS employee, an IRS spokesperson indicated that the IRS also declined to state whether Stack had been designated as a PDT.[6][7] Mark Pitcavage of the Anti-Defamation League called Stack a lone-wolf "homegrown, self-taught extremist" with possible ties to the Tax Protest Movement.[8]

This is a chart from an IRS report that shows data on quantities[9]

Calendar Year PDT Case Closures PDT Determinations CAU Case Closures CAU Determinations
2008 960 163 615 601
2009 989 136 706 695
2010 1,154 151 774 747
2011 1531 158 993 967
2012‡ 691 117 492 473

‡ 2012 is only up until July 2012

In 2009, Randy Nowak of Mulberry, Florida, was convicted and sentenced to 30 years in prison for attempting to hire a hitman to murder the IRS agent doing his audit.[10]

In other cases, disgruntled taxpayers have enclosed foreign objects with their returns.[6]

See also[edit]


  1. ^ "Disclosure of Customer's status as Potentially Dangerous Taxpayer or Caution Upon Contact Taxpayer UILC:6103.08-00, 7213.01-01" (PDF). US Internal Revenue Service. Retrieved 2012-06-26. 
  2. ^ a b Martin, Susan Taylor (February 22, 2010). "Some take ire for IRS too far". St. Petersburg Times. Retrieved March 3, 2010. 
  3. ^ a b "Part 25, Chapter 4, sec. 1, Internal Revenue Manual, Internal Revenue Service, U.S. Dep't of the Treasury". IRS.gov. July 8, 2009. Retrieved March 3, 2010. 
  4. ^ See Internal Revenue Manual, IRM 25.4.2 et seq., at [1].
  5. ^ Id.
  6. ^ a b Ball, Andrea (March 3, 2010). "Hatred toward IRS nothing new". The Dallas Morning News. Retrieved 2010-03-28. 
  7. ^ Ball, Andrea (March 1, 2010). "Threats, contempt come with job for IRS workers". Austin American-Statesman. Retrieved March 3, 2010. 
  8. ^ Martin, Susan Taylor (February 20, 2010). "Texas case is extreme example of how Americans hate the IRS". St. Petersburg Times. Retrieved March 3, 2010. 
  9. ^ http://www.treasury.gov/tigta/auditreports/2013reports/201340014fr.pdf
  10. ^ Ball, Andrea (March 8, 2010). "Just Coming to Work Can Be Dangerous for Federal Employees". The Ledger.