> ## Content Index
> Fetch the complete content index at: https://www.bodiesburied.com/llms.txt
> Use this file to discover other available public pages before exploring further.

# §2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: Federal Sentences, Fiscal Year 2021
- URL: https://www.bodiesburied.com/trends/federal-guideline-2t1-6-failing-to-collect-or-truthfully-account-for-fy2021/
- Published: 2026-11-04T10:28:35.000Z
- Updated: 2026-11-04T10:28:35.000Z
- Description: In fiscal year 2021, 12 of the 39 people sentenced under §2T1.6 (31%) were sentenced within the guideline range. 30 (77%) received a prison term, and the median prison term was 13 months. 38 people (97%) pleaded guilty.
- 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: FY2021

**In brief:** In fiscal year 2021, 12 of the 39 people sentenced under §2T1.6 (31%) were sentenced within the guideline range. 30 (77%) received a prison term, and the median prison term was 13 months. 38 people (97%) pleaded guilty.

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 39 people sentenced in federal court in fiscal year 2021\. 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/).

## Within-Range Sentences in Fiscal Year 2021

The U.S. Sentencing Commission counted 39 people in fiscal year 2021 whose primary guideline was §2T1.6, which the Guidelines Manual titles "Failing to Collect or Truthfully Account for and Pay Over Tax."

Within the guideline range: 31% (12 people). Below the range without a government request: 56% (22). Below the range at the government's request: 13% (5). Above the range: none.

The within-range share was higher than the 17% all-years share for this guideline and lower than the 43% share for every guideline in fiscal year 2021\. In fiscal year 2020 it was 4%, and in fiscal year 2022 it was 17%.

## Prison and Probation

30 of the 39 people (77%) were sentenced to prison, and 8 (21%) received probation only, with no prison or other confinement.

The median prison term among those sent to prison was 13 months. A quarter received 20.8 months or more, and a quarter received 9 months or less. No mandatory minimum prison term applied to any of the 39 (0%).

Supervised release was ordered for 30 people (77%), with a median term of 30 months.

| 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%            |

## Pleas

38 of the 39 people (97%) pleaded guilty, and 1 was convicted after a trial. 97% of the guilty pleas had a written plea agreement, and 3% were straight pleas with no agreement.

The median prison term was 12 months after a guilty plea and 36 months after a trial. The trial figure comes from 1 person and cannot be read as a general result.

Only convicted and sentenced people are in the data, so acquittals and dismissals are not reflected.

## Money Orders and Criminal History

Restitution was ordered for 34 people (87%), and a fine for 6 (15%). Amounts are not given.

85% of the group were in criminal history category I, the lowest. None (0%) were in category VI, the highest. Court-martial records have no criminal history field.

## Neighboring Years and the Federal System

Fiscal year 2020 had 28 people under §2T1.6 and a median prison term of 12 months. Fiscal year 2022 had 69 people and a median prison term of 12.5 months.

From fiscal years 2016 to 2025, 499 people were sentenced under this guideline. 69% went to prison, the median prison term was 12 months, and 97% pleaded guilty.

In fiscal year 2021, 57,287 people were sentenced in federal court under all guidelines. Their median prison term was 29 months, and 98% pleaded guilty. The Commission's offense type for these 39 cases is Tax.

## What the Records Cannot Show

The year covered is October 1, 2020 through September 30, 2021\. A group of 39 is small, and one year is not a trend. The approved crosswalk has no close court-martial counterpart for this guideline, so this post reports the federal numbers on their own.

The files carry no case facts and no stated reasons for sentences.

### How We Counted

Everyone sentenced in federal court in fiscal year 2021 whose primary sentencing guideline was §2T1.6 (39), 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 2020](https://www.bodiesburied.com/trends/federal-guideline-2t1-6-failing-to-collect-or-truthfully-account-for-fy2020/) (previous or next fiscal year)
- [§2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: Federal Sentences, Fiscal Year 2022](https://www.bodiesburied.com/trends/federal-guideline-2t1-6-failing-to-collect-or-truthfully-account-for-fy2022/) (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.