§2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, Fiscal Year 2018
Fiscal year 2018 had the largest group in the 2016 to 2025 record for §2T1.4: 195 people. A prison term went to 141 (72%), and the median was 24 months (2 years). A mandatory minimum prison term applied to 21 people (11%).
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Trends › Federal Prosecution Analysis › §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising › §2T1.4: FY2018
In brief: Fiscal year 2018 had the largest group in the 2016 to 2025 record for §2T1.4: 195 people. A prison term went to 141 (72%), and the median was 24 months (2 years). A mandatory minimum prison term applied to 21 people (11%).
This post uses the U.S. Sentencing Commission's records of 195 people sentenced in federal court in fiscal year 2018. 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.
The Largest Yearly Group Under §2T1.4
The Sentencing Commission counted 195 people sentenced in fiscal year 2018 with §2T1.4 as the primary guideline. The yearly table shows no other year from 2016 to 2025 with a higher count. The fiscal year ran from October 1, 2017 to September 30, 2018.
The guideline is titled "Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud." The Commission's offense type for these cases is Tax, with 195 people in the year.
Prison Terms in 2018
Prison was imposed on 141 of the 195 people (72%). Probation only, with no prison or other confinement, went to 39 (20%).
The median prison term for those sent to prison was 24 months (2 years). A quarter received 41 months or more, and a quarter received 12 months or less. These are terms imposed, not time served.
Trials and Pleas
Guilty pleas were entered by 178 people (91%), and 17 people were convicted after a trial. The median prison term after a guilty plea was 20 months. The median after a trial was 60 months, based on 16 people sent to prison.
Written plea agreements covered 97% of the guilty pleas, and 3% were straight pleas with no agreement. The records do not show what drove any person's choice to plead or go to trial.
Mandatory Minimums and Other Conditions
Of the 195 people, 21 (11%) had a mandatory minimum prison term apply. Supervised release followed prison for 138 people (71%), with a median term of 12 months.
Restitution was ordered for 180 people (92%), and a fine for 16 (8%).
Position Against the Guideline Range
Sentences within the range numbered 55 (28%). Sentences below the range at the government's request numbered 50 (26%), and sentences below the range without a government request numbered 88 (45%). Sentences above the range numbered 2 (1%).
In the lowest criminal history category, category I, were 78% of the group. In the highest, category VI, were 2%. Court-martial records have no criminal history field.
Context From Other Years and All Guidelines
Across fiscal years 2016 to 2025, 1,451 people were sentenced under §2T1.4. Of those, 71% went to prison, the median prison term was 21 months, 92% pleaded guilty, and 24% were within the range. The 2018 median of 24 months is higher than the median for all years.
In fiscal year 2017, 161 people were sentenced, with a median of 18 months and 22% within the range. In fiscal year 2019, 166 people were sentenced, with a median of 18 months and 22% within the range.
In 2018, 69,425 people were sentenced in federal court under every guideline. Their median prison term was 24 months, the same as here, and 51% were 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% |
What Is Missing
Acquittals and dismissals are outside this data, which covers only people convicted and sentenced. No close court-martial counterpart for this guideline exists in the approved crosswalk, so the federal numbers stand alone.
How We Counted
Everyone sentenced in federal court in fiscal year 2018 whose primary sentencing guideline was §2T1.4 (195), 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 2017 (previous or next fiscal year)
- §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, Fiscal Year 2019 (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.