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Marinello v. United States - Supreme Court Opinion

By Michael A. Villa, Jr. on March 21, 2018

The U.S. Supreme Court reversed a taxpayer’s conviction today under 26 U.S.C. § 7212(a), also known as the Omnibus Clause, which forbids “corruptly or by force or threats of force . . . obstruct[ing] or imped[ing], or endeavor[ing] to obstruct or impede, the due administration of [the Internal Revenue Code].”

The Court held that in order to convict a defendant under the Omnibus Clause the Government must prove the defendant was aware of a pending tax-related proceeding, such as a particular investigation or audit, or could reasonably foresee that such a proceeding would commence. The Court’s opinion is attached.