§2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, Fiscal Year 2017
In fiscal year 2017, 161 people were sentenced in federal court under §2T1.4, and every guilty plea came with a written plea agreement. A prison term went to 117 people (73%), with a median of 18 months. A mandatory minimum prison term applied to 11 people (7%).
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Trends › Federal Prosecution Analysis › §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising › §2T1.4: FY2017
In brief: In fiscal year 2017, 161 people were sentenced in federal court under §2T1.4, and every guilty plea came with a written plea agreement. A prison term went to 117 people (73%), with a median of 18 months. A mandatory minimum prison term applied to 11 people (7%).
This post uses the U.S. Sentencing Commission's records of 161 people sentenced in federal court in fiscal year 2017. 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.
Written Plea Agreements in Every Guilty Plea
Of the 161 people sentenced, 150 (93%) pleaded guilty, and 11 were convicted after a trial. The sheet records that 100% of the guilty pleas had a written plea agreement and 0% were straight pleas with no agreement.
The median prison term after a guilty plea was 18 months. After a trial, the median was 57 months, based on 11 people who were sent to prison. The records show the terms, but they do not show why a case went to trial or what a plea agreement contained.
The Group Sentenced in Fiscal Year 2017
The U.S. Sentencing Guidelines Manual titles §2T1.4 "Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud." The U.S. Sentencing Commission counted 161 people for whom it was the primary guideline in the fiscal year that ran from October 1, 2016 to September 30, 2017. The Commission files these cases under its Tax offense type.
Among the 161, 117 (73%) were sentenced to prison and 28 (17%) received probation only, with no prison or other confinement. The median prison term for those sent to prison was 18 months. A quarter received 36 months or more, and a quarter received 8 months or less.
Mandatory Minimums, Supervised Release, and Money Orders
A mandatory minimum prison term applied to 11 of the 161 people (7%). Supervised release was ordered for 116 people (72%), and the median term was 30 months.
Restitution was ordered for 150 people (93%). A fine was ordered for 9 people (6%).
Where the Sentences Fell Against the Guideline Range
Within the advisory range were 22% of sentences (36 people). Below the range at the government's request were 32% (51 people), and below the range without a government request were 45% (72 people). Above the range were 1% (2 people).
Most people had little criminal history. In category I, the lowest, were 73% of the group, and 3% were in category VI, the highest. Court-martial records have no criminal history field, so that measure has no military counterpart.
Comparison With Other Years and With All Guidelines
Over fiscal years 2016 to 2025, 1,451 people were sentenced under §2T1.4. Of those, 71% were sent to prison, the median prison term was 21 months, 92% pleaded guilty, and 24% were sentenced within the range. The 2017 median is lower than the median for all years, and the 22% within the range is lower than the 24%.
In fiscal year 2016, 181 people were sentenced, with a median of 24 months and 28% within the range. In fiscal year 2018, 195 people were sentenced, with a median of 24 months and 28% within the range.
All 66,873 people sentenced in federal court in 2017 under every guideline had a median prison term of 24 months, 97% pleaded guilty, and 49% were sentenced within the range.
| Fiscal year | People sentenced | Median prison | Pleaded guilty |
|---|---|---|---|
| 2016 | 181 | 24 months | 89% |
| 2017 | 161 | 18 months | 93% |
| 2018 | 195 | 24 months | 91% |
| 2019 | 166 | 18 months | 92% |
| 2020 | 121 | 21.5 months | 92% |
| 2021 | 138 | 18 months | 93% |
| 2022 | 139 | 20 months | 96% |
| 2023 | 126 | 24 months | 89% |
| 2024 | 112 | 20.5 months | 94% |
| 2025 | 112 | 24 months | 95% |
Limits on What the Numbers Show
The data counts only people who were convicted and sentenced. Acquittals and dismissed cases are not in it, and prison terms are the terms imposed, not time served.
The approved crosswalk has no close court-martial counterpart for this guideline, so the post reports federal numbers on their own. One year is a single data point and not a trend.
How We Counted
Everyone sentenced in federal court in fiscal year 2017 whose primary sentencing guideline was §2T1.4 (161), 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.
Mandatory minimum sentences. Many federal statutes on drugs, images of child exploitation, child sex abuse, and firearms carry mandatory minimum prison terms. The UCMJ has mandatory minimums only for a few offenses (a dishonorable discharge or dismissal for rape and sexual assault, and life for premeditated murder). Federal sentences for these offenses are partly set by Congress, not by the judge.
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)
- §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, FY2016–2025 (overview)
- §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, Fiscal Year 2016 (previous or next fiscal year)
- §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, Fiscal Year 2018 (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.