§2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, Fiscal Year 2023
In fiscal year 2023, the median prison term was 73 months for the 14 people convicted after a trial under §2T1.4, and 18 months for those who pleaded guilty. Of the 126 people sentenced under this guideline, 112 (89%) pleaded guilty. The median prison term for all 87 people sent to prison was 24 mon
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Trends › Federal Prosecution Analysis › §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising › §2T1.4: FY2023
In brief: In fiscal year 2023, the median prison term was 73 months for the 14 people convicted after a trial under §2T1.4, and 18 months for those who pleaded guilty. Of the 126 people sentenced under this guideline, 112 (89%) pleaded guilty. The median prison term for all 87 people sent to prison was 24 months.
This post uses the U.S. Sentencing Commission's records of 126 people sentenced in federal court in fiscal year 2023. 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.
Trial and Plea Medians in Fiscal Year 2023
Under §2T1.4, 14 of the 126 people sentenced in fiscal year 2023 were convicted after a trial. Their median prison term was 73 months. The 112 people (89%) who pleaded guilty had a median prison term of 18 months.
These groups are not matched. The records do not show the facts of each case or the charges that were dropped, so the gap shows only what was imposed on each group.
The Guideline and the Year
Guideline §2T1.4 is titled "Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud." The U.S. Sentencing Commission counted 126 people for whom it was the primary guideline in the fiscal year from October 1, 2022 to September 30, 2023. The Commission's offense type for these cases is Tax.
Among the 126, 87 (69%) received a prison term, and 32 (25%) received probation only, with no prison or other confinement.
Overall Prison Terms and Supervised Release
The median prison term for the 87 people sent to prison was 24 months (2 years). A quarter received 36 months or more, and a quarter received 12 months or less.
Supervised release was ordered for 88 people (70%), with a median term of 12 months. A mandatory minimum prison term applied to 3 people (2%).
Against the Guideline Range
Within the range were 17% (22 people), the lowest share among the fiscal years 2022 and 2024 that are listed beside this one. Below the range at the government's request were 32% (40 people), and below the range without a government request were 48% (60 people). Above the range were 3% (4 people).
Plea Agreements, Restitution, Fines, and Criminal History
Written plea agreements covered 96% of guilty pleas, and 4% were straight pleas with no agreement.
Restitution was ordered for 115 people (91%), and a fine for 20 (16%). In criminal history category I, the lowest, were 76% of the group, and category VI, the highest, held 0%. Court-martial records have no criminal history field.
Comparisons With All Years and All Guidelines
For 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 2023 median of 24 months is higher than the median for all years.
In fiscal year 2022, 139 people were sentenced, with a median of 20 months and 19% within the range. In fiscal year 2024, 112 people were sentenced, with a median of 20.5 months and 28% within the range.
In 2023, 64,124 people were sentenced under every guideline in federal court. Their median prison term was 30 months, guilty pleas were 97%, and 42% 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 the Data Cannot Establish
Only convicted and sentenced people are counted. Acquittals and dismissals are not included, and prison terms are those imposed. No close court-martial counterpart appears in the approved crosswalk, so this post reports federal numbers alone.
How We Counted
Everyone sentenced in federal court in fiscal year 2023 whose primary sentencing guideline was §2T1.4 (126), 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 2022 (previous or next fiscal year)
- §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, Fiscal Year 2024 (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.