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# §2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: Federal Sentences, Fiscal Year 2017
- URL: https://www.bodiesburied.com/trends/federal-guideline-2t1-6-failing-to-collect-or-truthfully-account-for-fy2017/
- Published: 2026-11-04T10:28:32.000Z
- Updated: 2026-11-04T10:28:32.000Z
- Description: Among the 47 people sentenced under §2T1.6 in fiscal year 2017, 46 (98%) pleaded guilty and 1 was convicted after a trial. The median prison term was 12 months after a guilty plea and 48 months after the one trial conviction. 32 people (68%) received a prison term.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › [§2T1.6 Failing to Collect or Truthfully Account for and Pay ](https://www.bodiesburied.com/trends/federal-guideline-2t1-6-failing-to-collect-or-truthfully-account-for/) › §2T1.6: FY2017

**In brief:** Among the 47 people sentenced under §2T1.6 in fiscal year 2017, 46 (98%) pleaded guilty and 1 was convicted after a trial. The median prison term was 12 months after a guilty plea and 48 months after the one trial conviction. 32 people (68%) received a prison term.

Updated November 4, 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 47 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](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/).

## One Trial Conviction Among 47 People

The U.S. Sentencing Commission counted 47 people in fiscal year 2017 whose primary guideline was §2T1.6\. The guideline is titled "Failing to Collect or Truthfully Account for and Pay Over Tax" in the Guidelines Manual.

46 of the 47 (98%) pleaded guilty, and 1 was convicted after a trial. All of the guilty pleas (100%) had a written plea agreement.

The median prison term after a guilty plea was 12 months. After a trial it was 48 months, but that figure rests on 1 person. It cannot be treated as a typical trial sentence.

The Commission counts only people who were convicted and sentenced. Acquittals and dismissals are not included.

## Prison Terms and Probation

32 of the 47 people (68%) were sentenced to prison. 9 (19%) received probation only, with no prison or other confinement.

Among those sent to prison, the median prison term was 12 months. A quarter received 18 months or more, and a quarter received 7.5 months or less. No mandatory minimum prison term applied to any of the 47 (0%).

## Range Positions

Below the range without a government request: 64% (30 people). Within the range: 21% (10). Below the range at the government's request: 15% (7). Above the range: none.

The within-range share was higher than the 17% all-years share for this guideline. It was lower than the 49% share for every guideline in fiscal year 2017.

| Fiscal year | People sentenced | Median prison | Pleaded guilty |
| ----------- | ---------------- | ------------- | -------------- |
| 2016        | 47               | 12 months     | 100%           |
| 2017        | 47               | 12 months     | 98%            |
| 2018        | 39               | 16.5 months   | 95%            |
| 2019        | 40               | 24 months     | 95%            |
| 2020        | 28               | 12 months     | 89%            |
| 2021        | 39               | 13 months     | 97%            |
| 2022        | 69               | 12.5 months   | 100%           |
| 2023        | 70               | 15 months     | 97%            |
| 2024        | 57               | 12 months     | 100%           |
| 2025        | 63               | 12 months     | 95%            |

## Supervised Release, Fines, and Restitution

32 people (68%) were ordered to serve supervised release after prison, and the median term was 36 months. A fine was ordered for 10 (21%). Restitution was ordered for 40 (85%).

The data lists only whether restitution was ordered, not the amount.

## Criminal History

89% were in criminal history category I, the lowest. None (0%) were in category VI, the highest. Court-martial records have no criminal history field.

## Surrounding Years and All Federal Cases

Fiscal year 2016 had 47 people under §2T1.6, a median prison term of 12 months, and 17% within the range. Fiscal year 2018 had 39 people, a median prison term of 16.5 months, and 13% within the range.

The all-years totals are 499 people, 69% sent to prison, a median prison term of 12 months, and 97% guilty pleas.

In fiscal year 2017, 66,873 people were sentenced in federal court under all guidelines, with a median prison term of 24 months and 97% guilty pleas. The Commission's offense type for the 47 cases here is Tax.

## What the Records Leave Out

Fiscal year 2017 ran from October 1, 2016 to September 30, 2017\. The approved crosswalk has no close court-martial counterpart for this guideline, so this post reports the federal numbers on their own.

The records do not give the facts of any case or the reasons for a sentence.

### How We Counted

Everyone sentenced in federal court in fiscal year 2017 whose primary sentencing guideline was §2T1.6 (47), 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](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)
- [§2T1.6 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/) (overview)
- [§2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: Federal Sentences, Fiscal Year 2016](https://www.bodiesburied.com/trends/federal-guideline-2t1-6-failing-to-collect-or-truthfully-account-for-fy2016/) (previous or next fiscal year)
- [§2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: Federal Sentences, Fiscal Year 2018](https://www.bodiesburied.com/trends/federal-guideline-2t1-6-failing-to-collect-or-truthfully-account-for-fy2018/) (previous or next fiscal year)
- [How Often Federal Judges Sentence Outside the Guideline Range](https://www.bodiesburied.com/trends/federal-sentences-outside-guideline-range/)
- [Mandatory Minimums: How Many Federal Sentences Are Set by Congress](https://www.bodiesburied.com/trends/federal-mandatory-minimum-sentences/)
- [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.