ISCR Case No. 25-00995

FOR GOVERNMENT Andrea M. Corrales, Esq., Deputy Chief Department Counsel FOR APPLICANT Pro se The Department of Defense (DoD) declined to grant Applicant a security clearance. On August 19, 2025, DoD issued a Statement of Reasons (SOR) advising Applicant of the basis of that decision – security concerns raised under Guideline F (Financial Considerations) of the National Security Adjudicative Guidelines (AG) in Appendix A of Security Executive Agent Directive 4 (effective June 8, 2017) and DoD Directive 5220.6 (Jan. 2, 1992, as amended) (Directive). The SOR was later amended to add additional Guideline F concerns. On July 7, 2026, Defense Office of Hearings and Appeals Administrative Judge Mark Harvey denied Applicant national security eligibility. Applicant appealed pursuant to Directive ¶¶ E3.1.28 and E3.1.30. Background Applicant, in her mid-40s, has been married since 2003 and has five children. She earned a bachelor’s degree in 2004, a master’s degree in 2019, and a Ph.D. in 2023. Applicant seeks initial national security eligibility for her employment with a government contractor, for whom she has worked since August 2024.

The SOR, as amended, alleged that Applicant carried delinquent tax balances for tax years 2021 through 2024, which totaled approximately $53,400 owed to the federal government and approximately $15,600 owed to a state tax authority. In her September 2025 response to the SOR, Applicant denied the allegations on the basis that the delinquent taxes were being addressed via payment plans. Applicant attributed her tax debts to insufficient income withholding beginning when she started new employment in July 2020, which resulted in balances owed when she prepared her 2021 tax returns. Due to the additional balances owed, she delayed filing her 2021 and 2022 returns until August 2024. Applicant’s evidence reflected payments made to the state tax authority, including $290 per month from October 2024 to March 2025, followed by eight lump sum payments in April and May 2026 that ultimately resolved the outstanding balance. Finding the state tax allegations paid and mitigated, the Judge resolved the two corresponding SOR concerns favorably. Turning to the federal tax debt, the Judge found that Applicant entered into an installment agreement in about September 2024, following which she made one $600 payment in November 2024, monthly payments of $630 from January to July 2025, and one $652 payment in September 2025; however, the installment agreement was terminated as of November 2025.1 As of June 2026, the federal tax balance was approximately $50,900, and Applicant had a new installment agreement with monthly payments of $700 scheduled to begin that month through bank debit. The Judge addressed the timing of Applicant’s tax resolution efforts as potentially related to her seeking national security eligibility, noting that Applicant submitted her security clearance application on August 13, 2024, filed her 2021 and 2022 federal tax returns two days later, and established a federal installment agreement the following month. Additionally, while she initiated payments under that agreement in January 2025, monthly payments stopped after July 2025. After the SOR was issued in August, Applicant made one additional voluntary payment outside of the installment agreement in September 2025. The Judge also addressed Applicant’s finances generally, noting that her husband borrowed $17,000 from his retirement account, in part to pay their state tax balance, which required a monthly repayment of $200. Her husband’s income had also increased substantially over the prior three years, and the couple had about $30,000 in savings, which they wanted to maintain in case of medical emergency. The Judge credited Applicant for having filed all outstanding federal tax returns and for having established the latest federal installment agreement, but he also noted the family’s financial resources that have not been used to address the federal tax balance, which continues to accrue interest without a clear timeframe for repayment. Overall, the Judge concluded that “Applicant failed to prove that she took sufficient timely, prudent, responsible, and good-faith actions regarding her [federal income taxes] from 2021 to 2024” and that her “behavior over multiple years raises unmitigated questions about her reliability, trustworthiness, and ability to protect classified information.” Decision at 12. 1 The Judge found that, after the federal installment agreement terminated in November 2025, Applicant made payments of several hundred dollars each in 2025 and 2026; however, the evidence reflects that three of those payments, made in December 2025 and March and April 2026, were overpayments transferred in from other tax years and not voluntary payments. See Applicant Exhibit (AE) B at 2; AE F. 2

Discussion Applicant does not challenge any of the Judge’s specific findings of fact on appeal. Rather, she argues that the Judge failed to properly analyze her resolution efforts and the timing thereof and failed to sufficiently assess the Whole-Person Concept factors. For the following reasons, Applicant’s arguments are not persuasive, and we affirm the Judge’s decision. Carrying throughout her appeal is Applicant’s overarching contention that the Judge afforded insufficient weight to her 2025 federal tax return, which was timely filed, reflected appropriate withholding, and resulted in a refund of about $1,000. Unpersuaded, we note generally that Applicant’s arguments advocate for an alternative weighing of the evidence, which is insufficient to demonstrate that the Judge weighed the evidence or reached conclusions in a manner that is arbitrary, capricious, or contrary to law. See ISCR Case No. 04-08975, 2006 WL 2725032 at *1 (App. Bd. Aug. 4, 2006). For example, Applicant challenges the Judge’s finding that, despite her assertion that she increased her withholding “at least twice” after 2020, those amounts for 2021 and 2022 “were not adequate to ensure her taxes were paid when due without a substantial payment when her tax returns were filed.” Decision at 3. Applicant argues that the Judge relied too narrowly on her 2021 and 2022 withholding amounts as refuting that she eventually corrected her withholding, and she advocates instead for greater weight to be given to her 2025 withholding, which was more than sufficient to cover the tax owed for that year. While Applicant indeed addressed her problematic withholding in the latest tax year, her argument overlooks intervening tax years 2023 and 2024, for which her withholding amounts remained insufficient and led to tax balances owed of about $9,200 and $6,300, respectively. The Judge’s finding that, from tax year 2021 to 2024, “Applicant failed to withhold sufficient income or pay her [federal income taxes] when due” is supported by the record, and he properly included this inaction in his analysis of Applicant’s “overall handling” of her taxes to conclude that security concerns remained. Id. at 11. Applicant also challenges the Judge’s analysis under the Whole-Person Concept and, citing the factors that address rehabilitation and the likelihood that an issue will recur, argues that he failed to consider the 2025 tax return as “the most probative evidence available on recurrence.” Appeal Brief at 8. Here again, Applicant simply disagrees with the weight the Judge assigned to the 2025 return versus the four others that immediately preceded it. It is well established that a “meaningful financial track record” of resolution and repayment efforts is necessary to establish a mitigating good-faith effort to resolve debts. See ISCR Case No. 01-21386, 2003 WL 21979739 at *2 (App. Bd. Jun. 11, 2003). The Judge’s conclusion that Applicant’s recent and inconsistent tax resolution efforts were insufficient to establish such a track record or rehabilitation to fully mitigate the financial concerns was reasonable and sustainable. The Whole-Person Concept requires a judge to analyze an applicant’s circumstances based on consideration of the full record; however, a judge is not required to discuss each factor, and a decision does not turn simply on finding that one or more of them apply to the facts of a particular case. See ISCR Case No. 11-08546, 2013 WL 1103047 at *3 (App. Bd. Feb. 27, 2013) (citations omitted). In the instant case, the Judge evaluated Applicant’s security concerns in light of the entirety of the evidence, as is required for a Whole-Person analysis, and we find no basis to conclude that his evaluation was insufficient given the record before him. 3

Finally, Applicant argues that the Judge improperly considered the untimeliness of her 2021 and 2022 federal tax return filings, which were not alleged in the SOR. She argues that she was prejudiced because she had “no notice that the timeliness of her filings would become a contested issue, and accordingly developed no record on it,” such as when the returns were prepared or the circumstances of the delay. Appeal Brief at 12. Contrary to Applicant’s argument and as the Judge correctly identified, we have held that conduct not alleged in an SOR may still be relevant and considered for other purposes, such as evaluating an applicant’s credibility, rehabilitation, or case in mitigation. See ISCR Case No. 03-20327, 2006 WL 3545116 at *3 (App. Bd. Oct. 26, 2006). The Judge specifically noted this limited purpose and identified that he would consider the filing failures only in his mitigation and Whole-Person analyses. Indeed, his subsequent analysis of Applicant’s federal tax problems focuses on her continued inaction to address the withholding issue over four tax years, despite identifying her inability to pay the resulting lump sum annual tax balance, and relatively recent and short-term resolution efforts. Whatever limited consideration the Judge afforded to Applicant’s untimely tax return filings appears well within the bounds of the precedent to which he cites. Conclusion Applicant has not established that the Judge’s conclusions were arbitrary, capricious, or contrary to law. The Judge examined the relevant evidence, weighed the disqualifying and mitigating evidence, and articulated a satisfactory explanation for the decision. The record is sufficient to support that the Judge’s findings and conclusions are sustainable. “The general standard is that a clearance may be granted only when ‘clearly consistent with the interests of the national security.’” Dep’t of the Navy v. Egan, 484 U.S. 518, 528 (1988). “Any doubt concerning personnel being considered for national security eligibility will be resolved in favor of the national security.” AG ¶ 2(b). 4

Order The decision in ISCR Case No. 25-00995 is AFFIRMED. Signed: Moira Modzelewski Moira Modzelewski Administrative Judge Chair, Appeal Board Signed: Allison Marie Allison Marie Administrative Judge Member, Appeal Board Signed: Eric H. Borgstrom Eric H. Borgstrom Administrative Judge Member, Appeal Board 5

FOR APPLICANT Pro se The Department of Defense (DoD) declined to grant Applicant a security clearance. On August 19, 2025, DoD issued a Statement of Reasons (SOR) advising Applicant of the basis of that decision – security concerns raised under Guideline F (Financial Considerations) of the National Security Adjudicative Guidelines (AG) in Appendix A of Security Executive Agent Directive 4 (effective June 8, 2017) and DoD Directive 5220.6 (Jan. 2, 1992, as amended) (Directive). The SOR was later amended to add additional Guideline F concerns. On July 7, 2026, Defense Office of Hearings and Appeals Administrative Judge Mark Harvey denied Applicant national security eligibility. Applicant appealed pursuant to Directive ¶¶ E3.1.28 and E3.1.30. Background Applicant, in her mid-40s, has been married since 2003 and has five children. She earned a bachelor’s degree in 2004, a master’s degree in 2019, and a Ph.D. in 2023. Applicant seeks initial national security eligibility for her employment with a government contractor, for whom she has worked since August 2024.

The SOR, as amended, alleged that Applicant carried delinquent tax balances for tax years 2021 through 2024, which totaled approximately $53,400 owed to the federal government and approximately $15,600 owed to a state tax authority. In her September 2025 response to the SOR, Applicant denied the allegations on the basis that the delinquent taxes were being addressed via payment plans. Applicant attributed her tax debts to insufficient income withholding beginning when she started new employment in July 2020, which resulted in balances owed when she prepared her 2021 tax returns. Due to the additional balances owed, she delayed filing her 2021 and 2022 returns until August 2024. Applicant’s evidence reflected payments made to the state tax authority, including $290 per month from October 2024 to March 2025, followed by eight lump sum payments in April and May 2026 that ultimately resolved the outstanding balance. Finding the state tax allegations paid and mitigated, the Judge resolved the two corresponding SOR concerns favorably. Turning to the federal tax debt, the Judge found that Applicant entered into an installment agreement in about September 2024, following which she made one $600 payment in November 2024, monthly payments of $630 from January to July 2025, and one $652 payment in September 2025; however, the installment agreement was terminated as of November 2025.1 As of June 2026, the federal tax balance was approximately $50,900, and Applicant had a new installment agreement with monthly payments of $700 scheduled to begin that month through bank debit. The Judge addressed the timing of Applicant’s tax resolution efforts as potentially related to her seeking national security eligibility, noting that Applicant submitted her security clearance application on August 13, 2024, filed her 2021 and 2022 federal tax returns two days later, and established a federal installment agreement the following month. Additionally, while she initiated payments under that agreement in January 2025, monthly payments stopped after July 2025. After the SOR was issued in August, Applicant made one additional voluntary payment outside of the installment agreement in September 2025. The Judge also addressed Applicant’s finances generally, noting that her husband borrowed $17,000 from his retirement account, in part to pay their state tax balance, which required a monthly repayment of $200. Her husband’s income had also increased substantially over the prior three years, and the couple had about $30,000 in savings, which they wanted to maintain in case of medical emergency. The Judge credited Applicant for having filed all outstanding federal tax returns and for having established the latest federal installment agreement, but he also noted the family’s financial resources that have not been used to address the federal tax balance, which continues to accrue interest without a clear timeframe for repayment. Overall, the Judge concluded that “Applicant failed to prove that she took sufficient timely, prudent, responsible, and good-faith actions regarding her [federal income taxes] from 2021 to 2024” and that her “behavior over multiple years raises unmitigated questions about her reliability, trustworthiness, and ability to protect classified information.” Decision at 12. 1 The Judge found that, after the federal installment agreement terminated in November 2025, Applicant made payments of several hundred dollars each in 2025 and 2026; however, the evidence reflects that three of those payments, made in December 2025 and March and April 2026, were overpayments transferred in from other tax years and not voluntary payments. See Applicant Exhibit (AE) B at 2; AE F. 2

Discussion Applicant does not challenge any of the Judge’s specific findings of fact on appeal. Rather, she argues that the Judge failed to properly analyze her resolution efforts and the timing thereof and failed to sufficiently assess the Whole-Person Concept factors. For the following reasons, Applicant’s arguments are not persuasive, and we affirm the Judge’s decision. Carrying throughout her appeal is Applicant’s overarching contention that the Judge afforded insufficient weight to her 2025 federal tax return, which was timely filed, reflected appropriate withholding, and resulted in a refund of about $1,000. Unpersuaded, we note generally that Applicant’s arguments advocate for an alternative weighing of the evidence, which is insufficient to demonstrate that the Judge weighed the evidence or reached conclusions in a manner that is arbitrary, capricious, or contrary to law. See ISCR Case No. 04-08975, 2006 WL 2725032 at *1 (App. Bd. Aug. 4, 2006). For example, Applicant challenges the Judge’s finding that, despite her assertion that she increased her withholding “at least twice” after 2020, those amounts for 2021 and 2022 “were not adequate to ensure her taxes were paid when due without a substantial payment when her tax returns were filed.” Decision at 3. Applicant argues that the Judge relied too narrowly on her 2021 and 2022 withholding amounts as refuting that she eventually corrected her withholding, and she advocates instead for greater weight to be given to her 2025 withholding, which was more than sufficient to cover the tax owed for that year. While Applicant indeed addressed her problematic withholding in the latest tax year, her argument overlooks intervening tax years 2023 and 2024, for which her withholding amounts remained insufficient and led to tax balances owed of about $9,200 and $6,300, respectively. The Judge’s finding that, from tax year 2021 to 2024, “Applicant failed to withhold sufficient income or pay her [federal income taxes] when due” is supported by the record, and he properly included this inaction in his analysis of Applicant’s “overall handling” of her taxes to conclude that security concerns remained. Id. at 11. Applicant also challenges the Judge’s analysis under the Whole-Person Concept and, citing the factors that address rehabilitation and the likelihood that an issue will recur, argues that he failed to consider the 2025 tax return as “the most probative evidence available on recurrence.” Appeal Brief at 8. Here again, Applicant simply disagrees with the weight the Judge assigned to the 2025 return versus the four others that immediately preceded it. It is well established that a “meaningful financial track record” of resolution and repayment efforts is necessary to establish a mitigating good-faith effort to resolve debts. See ISCR Case No. 01-21386, 2003 WL 21979739 at *2 (App. Bd. Jun. 11, 2003). The Judge’s conclusion that Applicant’s recent and inconsistent tax resolution efforts were insufficient to establish such a track record or rehabilitation to fully mitigate the financial concerns was reasonable and sustainable. The Whole-Person Concept requires a judge to analyze an applicant’s circumstances based on consideration of the full record; however, a judge is not required to discuss each factor, and a decision does not turn simply on finding that one or more of them apply to the facts of a particular case. See ISCR Case No. 11-08546, 2013 WL 1103047 at *3 (App. Bd. Feb. 27, 2013) (citations omitted). In the instant case, the Judge evaluated Applicant’s security concerns in light of the entirety of the evidence, as is required for a Whole-Person analysis, and we find no basis to conclude that his evaluation was insufficient given the record before him. 3

Finally, Applicant argues that the Judge improperly considered the untimeliness of her 2021 and 2022 federal tax return filings, which were not alleged in the SOR. She argues that she was prejudiced because she had “no notice that the timeliness of her filings would become a contested issue, and accordingly developed no record on it,” such as when the returns were prepared or the circumstances of the delay. Appeal Brief at 12. Contrary to Applicant’s argument and as the Judge correctly identified, we have held that conduct not alleged in an SOR may still be relevant and considered for other purposes, such as evaluating an applicant’s credibility, rehabilitation, or case in mitigation. See ISCR Case No. 03-20327, 2006 WL 3545116 at *3 (App. Bd. Oct. 26, 2006). The Judge specifically noted this limited purpose and identified that he would consider the filing failures only in his mitigation and Whole-Person analyses. Indeed, his subsequent analysis of Applicant’s federal tax problems focuses on her continued inaction to address the withholding issue over four tax years, despite identifying her inability to pay the resulting lump sum annual tax balance, and relatively recent and short-term resolution efforts. Whatever limited consideration the Judge afforded to Applicant’s untimely tax return filings appears well within the bounds of the precedent to which he cites. Conclusion Applicant has not established that the Judge’s conclusions were arbitrary, capricious, or contrary to law. The Judge examined the relevant evidence, weighed the disqualifying and mitigating evidence, and articulated a satisfactory explanation for the decision. The record is sufficient to support that the Judge’s findings and conclusions are sustainable. “The general standard is that a clearance may be granted only when ‘clearly consistent with the interests of the national security.’” Dep’t of the Navy v. Egan, 484 U.S. 518, 528 (1988). “Any doubt concerning personnel being considered for national security eligibility will be resolved in favor of the national security.” AG ¶ 2(b). 4

Order The decision in ISCR Case No. 25-00995 is AFFIRMED. Signed: Moira Modzelewski Moira Modzelewski Administrative Judge Chair, Appeal Board Signed: Allison Marie Allison Marie Administrative Judge Member, Appeal Board Signed: Eric H. Borgstrom Eric H. Borgstrom Administrative Judge Member, Appeal Board 5