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# §2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, FY2016–2025
- URL: https://www.bodiesburied.com/trends/federal-guideline-2t1-4-aiding-assisting-procuring-counseling-or-advising-tax/
- Published: 2026-11-03T01:39:45.000Z
- Updated: 2026-11-03T01:39:45.000Z
- Description: Under §2T1.4, Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud, 1,451 people were sentenced in fiscal years 2016 to 2025. Sentences below the guideline range without a government request were the largest single group at 47%, and the median prison term was 21 months.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › §2T1.4

**In brief:** Under §2T1.4, Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud, 1,451 people were sentenced in fiscal years 2016 to 2025\. Sentences below the guideline range without a government request were the largest single group at 47%, and the median prison term was 21 months.

Updated November 2, 2026 · Sources: U.S. Sentencing Commission and Federal Judicial Center, fiscal years 2016–2025

This post uses the U.S. Sentencing Commission's records of 1,451 people sentenced in federal court in fiscal years 2016 to 2025\. 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](https://www.bodiesburied.com/trends/federal/) series, which builds on [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/). How the numbers were built: [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/).

## How Sentences Compared With the Guideline Range

The Commission recorded the sentence position for all 1,451 people. Within the guideline range was 24% (346).

Below the range at the government's request was 28% (402), and below the range without a government request was 47% (685). Above the range was 1% (18).

Sentences below the range without a government request were the largest single group. The records cannot show the reasons in individual cases.

Sentences within the range were less common here than sentences below it, whether or not the government asked for the lower sentence.

## What Does Guideline §2T1.4 Cover?

The Sentencing Guidelines Manual titles §2T1.4 "Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud." The U.S. Sentencing Commission files the cases under Tax.

Each person counted had §2T1.4 as the primary guideline, the one that set the offense level for the most serious count. The data includes only people who were convicted and sentenced.

## Prison and Probation

A prison term went to 1,024 people (71%), and probation only, with no prison or other confinement, went to 303 (21%).

The median prison term was 21 months. A quarter received 36 months or more, and a quarter received 12 months or less. These are terms imposed, not time served.

## Pleas and Trials

A total of 1,338 people (92%) pleaded guilty, and 113 were convicted after a trial. The median prison term was 18 months after a guilty plea. After a trial it was 53 months, based on 110 people convicted at trial and sent to prison.

Among guilty pleas, 97% had a written plea agreement and 3% were straight pleas.

## Mandatory Minimums, Supervised Release, and Restitution

A mandatory minimum prison term applied to 54 people (4%).

Supervised release after prison was ordered for 1,015 people (70%), with a median term of 12 months.

Restitution was ordered for 1,324 people (91%), and a fine for 151 (10%). In criminal history, 76% were in category I, the lowest, and 2% were in category VI, the highest.

## Changes Over the Years

The count was 703 people in fiscal years 2016 to 2019 and 748 in fiscal years 2020 to 2025\. The median prison term was 21 months in both periods.

Yearly medians moved between 18 months in 2017, 2019, and 2021 and 24 months in 2016, 2018, 2023, and 2025\. The share who pleaded guilty ranged from 89% to 96%. The table lists each year.

| 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 Records Cannot Show

The approved crosswalk lists no close court-martial counterpart, so this post reports federal numbers only. The data does not show the amount of tax involved or what role each person had. It also does not show how many people were charged but not convicted, since only convictions are counted.

The yearly counts are small, between 112 and 195 people, so a single-year median can move with a few cases.

### How We Counted

Everyone sentenced in federal court in fiscal years 2016 to 2025 whose primary sentencing guideline was §2T1.4 (1,451), from the U.S. Sentencing Commission's 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](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/) (the background article)
- [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) (all federal posts)
- [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/) (sources and method)
- [§2T1.1 Tax Evasion: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2t1-1-tax-evasion/) (same guideline chapter part)
- [§2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2t1-6-failing-to-collect-or-truthfully-account-for/) (same guideline chapter part)
- [§2T3.1 Evading Import Duties or Restrictions (Smuggling): Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2t3-1-evading-import-duties-or-restrictions-smuggling/) (same guideline chapter part)
- [§2T1.9 Conspiracy to Impede, Impair, Obstruct, or Defeat Tax: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2t1-9-conspiracy-to-impede-impair-obstruct-or-defeat/) (same guideline chapter part)
- [U.S. Sentencing Commission, Individual Offender Datafiles](https://www.ussc.gov/research/datafiles/commission-datafiles?ref=bodiesburied.com) (source)
- [Federal Judicial Center, Integrated Database (criminal defendants)](https://www.fjc.gov/research/idb?ref=bodiesburied.com) (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](https://www.ucmj-defender.com/?ref=bodiesburied.com). This analysis is for education and information only. It is not legal advice, and every case is different.