§2T1.1 Tax Evasion: Federal Sentences, Fiscal Year 2024
Of the 248 people sentenced in federal court in fiscal year 2024 with §2T1.1 as the primary guideline, 155 (63%) received a prison term. The median prison term was 12 months. 73 sentences (29%) were within the guideline range.
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In brief: Of the 248 people sentenced in federal court in fiscal year 2024 with §2T1.1 as the primary guideline, 155 (63%) received a prison term. The median prison term was 12 months. 73 sentences (29%) were within the guideline range.
This post uses the U.S. Sentencing Commission's records of 248 people sentenced in federal court in fiscal year 2024. Acquittals and dismissals come from a second source, the Federal Judicial Center's records of 753,808 federal defendants whose cases ended in fiscal years 2016 to 2025. It is part of the Federal Prosecution Analysis series, which builds on Military Moves Toward Sentencing Guidelines to Mirror the Federal System. How the numbers were built: How the Federal Comparison Data Was Built.
Prison Terms Under §2T1.1 in Fiscal Year 2024
A prison term went to 155 of the 248 people (63%), and 68 (27%) received probation only, with no prison or other confinement. The 63% share is the same as the share for all fiscal years 2016 to 2025 under this guideline.
The median prison term was 12 months. A quarter of those sent to prison received 24 months or more, and a quarter received 6 months or less. The all-years median is 14 months.
What the Guideline Covers
The guideline is titled "Tax Evasion; Willful Failure to File Return, Supply Information, or Pay Tax; Fraudulent or False Returns, Statements, or Other Documents" in the U.S. Sentencing Guidelines Manual. A case appears here when this guideline set the offense level for its most serious count. The Commission's offense type for all 248 cases is Tax.
Fiscal year 2024 ran from October 1, 2023 to September 30, 2024. Only people convicted and sentenced are counted.
Where Sentences Fell Against the Range
Within the range: 29% (73 people). Below the range at the government's request: 27% (67). Below the range without a government request: 44% (108). Above the range: 0%.
Sentences under this guideline were within the range less often than the 46% for everyone sentenced in federal court in fiscal year 2024. In fiscal year 2023, 16% of sentences under §2T1.1 were within the range, and in fiscal year 2025 the figure was 25%.
Plea Agreements and Trials
Guilty pleas accounted for 230 of the 248 people (93%), and 18 were convicted after a trial. Of the guilty pleas, 96% had a written plea agreement, and 4% were straight pleas with no agreement.
After a guilty plea, the median prison term was 12 months. After a trial it was 33 months, based on 17 people convicted at trial and sent to prison. No mandatory minimum applied to any of the 248 people with that information recorded.
Supervised Release, Fines, and Restitution
Supervised release after prison was ordered for 152 people (61%), and the median term was 24 months. A fine was ordered for 78 (31%). Restitution was ordered for 229 (92%).
Of those sentenced, 90% were in the lowest criminal history category. Court-martial records have no criminal history field.
The Years Around 2024
Fiscal year 2023 had 237 people with a median prison term of 12 months. Fiscal year 2025 had 212 people with a median prison term of 15 months. The table lists each year, and the counts in each are modest, so the differences are not treated as a trend.
| Fiscal year | People sentenced | Median prison | Pleaded guilty |
|---|---|---|---|
| 2016 | 414 | 15 months | 93% |
| 2017 | 437 | 15 months | 91% |
| 2018 | 322 | 12 months | 93% |
| 2019 | 328 | 18 months | 94% |
| 2020 | 203 | 12 months | 91% |
| 2021 | 232 | 14.8 months | 96% |
| 2022 | 262 | 12 months | 94% |
| 2023 | 237 | 12 months | 91% |
| 2024 | 248 | 12 months | 93% |
| 2025 | 212 | 15 months | 96% |
What the Records Leave Out
The approved crosswalk has no close court-martial counterpart for this guideline, so this post reports the federal numbers on their own. The data do not show the amount of tax involved, the facts of any case, or what led a court to sentence below the range. Prison terms are those imposed, not time served.
How We Counted
Everyone sentenced in federal court in fiscal year 2024 whose primary sentencing guideline was §2T1.1 (248), U.S. Sentencing Commission individual data files. The primary guideline is the one that set the offense level for the most serious count.
Federal fiscal years run from October 1 to September 30. No person, judge, or lawyer is identified in any of these records.
What to Keep in Mind
No parole in federal prison; credit for good conduct. Federal prison has no parole for crimes committed on or after November 1, 1987. A federal prisoner can earn up to 54 days of good conduct credit for each year of the sentence the judge imposed, which is about 15%. Some federal prisoners can also earn First Step Act time credits, but many offenses make a person ineligible. The numbers in this post are the sentences judges imposed, not the time people actually served.
Federal supervised release. Most federal prison sentences are followed by a term of supervised release that the judge sets as part of the sentence. A person who violates it can be sent back to prison. A court-martial cannot sentence anyone to supervision after release. Military parole and mandatory supervised release are decided later by a board, not by the judge at trial.
Who decides the sentence, and under what rules. Federal judges sentence every federal case. They must calculate the Sentencing Guidelines range, which is advisory, and must impose any mandatory minimum the statute requires unless an exception applies. In courts-martial, the accused could choose sentencing by members until the rules changed. For cases in which every guilty finding is for an offense committed after December 27, 2023, a military judge sentences alone, within sentencing parameters. Courts-martial tried in 2024 and later include both old-rule and new-rule cases, and the data cannot tell them apart.
Time periods. Federal numbers are by federal fiscal year (October 1 to September 30), based on the sentencing date. The military numbers are by trial date. Neither source has the date of the offense, so a change in law shows up in either data set gradually.
How life sentences and "time served" are counted. In the federal numbers, a life sentence is counted as 470 months, and any other sentence longer than 470 months is counted as just under 470 months. A sentence of "time served" is counted as one day (0.03 months). Averages are affected by these rules; medians much less.
Related Analysis
- Military Moves Toward Sentencing Guidelines to Mirror the Federal System (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- §2T1.1 Tax Evasion: Federal Sentences, FY2016–2025 (overview)
- §2T1.1 Tax Evasion: Federal Sentences, Fiscal Year 2023 (previous or next fiscal year)
- §2T1.1 Tax Evasion: Federal Sentences, Fiscal Year 2025 (previous or next fiscal year)
- How Often Federal Judges Sentence Outside the Guideline Range
- Mandatory Minimums: How Many Federal Sentences Are Set by Congress
- U.S. Sentencing Commission, Individual Offender Datafiles (source)
- Federal Judicial Center, Integrated Database (criminal defendants) (source)
About the author. Jocelyn C. Stewart is a retired Army JAG with more than 24 years of trying courts-martial and more than 200 jury trials. She hosts Where All The Bodies Are Buried and runs the Law Office of Jocelyn C. Stewart. This analysis is for education and information only. It is not legal advice, and every case is different.