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:
Taxpayers who have committed acts of violence against IRS employees, contractors and/or their families;
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;
Taxpayers who are actively involved in groups which promote violence against IRS or other government employees;
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
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:
Threat of physical harm that is less severe or immediate than necessary to satisfy PDT [potentially dangerous taxpayer] criteria;
Suicide threat by the taxpayer; or
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]
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]