§2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: Federal Sentences, Fiscal Year 2025
63 people were sentenced under §2T1.6 in fiscal year 2025. 47 (75%) received a prison term, with a median of 12 months. 60 (95%) pleaded guilty, and 3 were convicted after a trial.
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Trends › Federal Prosecution Analysis › §2T1.6 Failing to Collect or Truthfully Account for and Pay › §2T1.6: FY2025
In brief: 63 people were sentenced under §2T1.6 in fiscal year 2025. 47 (75%) received a prison term, with a median of 12 months. 60 (95%) pleaded guilty, and 3 were convicted after a trial.
This post uses the U.S. Sentencing Commission's records of 63 people sentenced in federal court in fiscal year 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 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.
Prison Terms in Fiscal Year 2025
The U.S. Sentencing Commission counted 63 people whose primary guideline was §2T1.6, which the Guidelines Manual titles "Failing to Collect or Truthfully Account for and Pay Over Tax." Of these, 47 (75%) were sentenced to prison and 11 (17%) received probation only.
The median prison term was 12 months. A quarter of those sent to prison received 24 months or more, and a quarter received 11 months or less. The figures are the terms imposed, not time served.
Supervised release after prison was ordered for 47 people (75%). The median term was 36 months. A mandatory minimum prison term applied to 0 of the 63 people with that information recorded.
| 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% |
How Did Plea and Trial Cases Compare?
60 of the 63 people (95%) pleaded guilty. 3 were convicted after a trial. The median prison term was 12 months after a guilty plea and 12 months after a trial. The trial figure is based on only 3 people, so it says little on its own.
Among guilty pleas, 98% had a written plea agreement and 2% were straight pleas. Acquittals and dismissals are not in the Commission's data, so the records cannot show how many trials ended without a conviction.
Position Against the Guideline Range
31 people (49%) were sentenced below the range without a government request, and 19 (30%) were below it at the government's request. 12 (19%) were within the range, and 1 (2%) was above it.
The within-range share for this guideline across fiscal years 2016 to 2025 was 17%. For all guidelines in fiscal year 2025 it was 51%. Fiscal year 2024 had 9% within the range for this guideline, which is lower than the 19% in fiscal year 2025.
Restitution, Fines, and Criminal History
Restitution was ordered for 59 people (94%). A fine was ordered for 14 (22%). Dollar amounts are not part of these figures.
89% were in criminal history category I, the lowest, and 0% were in category VI, the highest. Court-martial records have no criminal history field.
The Wider Federal Numbers
Over 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.
All guidelines combined in fiscal year 2025 covered 66,662 people, with a median prison term of 24 months and 98% guilty pleas. The Commission classifies the 63 cases here as the offense type Tax. In fiscal year 2024 this guideline had 57 people and a median prison term of 12 months.
Scope and Limits
Fiscal year 2025 ran from October 1, 2024 to September 30, 2025. The approved crosswalk has no close court-martial counterpart for this guideline, so the post reports federal numbers only. The records do not describe individual cases or explain any sentence.
How We Counted
Everyone sentenced in federal court in fiscal year 2025 whose primary sentencing guideline was §2T1.6 (63), 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 (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- §2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: Federal Sentences, FY2016–2025 (overview)
- §2T1.6 Failing to Collect or Truthfully Account for and Pay Over Tax: 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.