> ## 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. # §2T2.1 Non-Payment of Taxes: Federal Sentences, FY2016–2025 - URL: https://www.bodiesburied.com/trends/federal-guideline-2t2-1-non-payment-of-taxes/ - Published: 2026-11-03T01:40:16.000Z - Updated: 2026-11-03T01:40:16.000Z - Description: Among 17 people sentenced under guideline §2T2.1 in fiscal years 2016 to 2023, 14 (82%) received a prison term. The median prison term was 17 months. All 17 pleaded guilty, and restitution was ordered in all 17 cases. - Author: Jocelyn C. Stewart - Tags: Understanding Trends, Federal [Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › §2T2.1 **In brief:** Among 17 people sentenced under guideline §2T2.1 in fiscal years 2016 to 2023, 14 (82%) received a prison term. The median prison term was 17 months. All 17 pleaded guilty, and restitution was ordered in all 17 cases. 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 17 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/). ## Restitution in Every Case Restitution was ordered for 17 of the 17 people (100%) sentenced under §2T2.1\. No fine was ordered for any of them. This is the most uniform feature in the data for this guideline. The sheet does not say who was paid or how much. ## What §2T2.1 Covers The Sentencing Guidelines Manual titles the section "Non-Payment of Taxes." The Sentencing Commission classes all 17 cases as Tax offenses. The U.S. Sentencing Commission counted these people as those whose primary guideline was §2T2.1\. The primary guideline is the one that set the offense level for the most serious count. ## Prison Terms and Their Range Of the 17 people, 14 (82%) were sentenced to prison and 1 (6%) received probation only. The median prison term was 17 months. A quarter of the people sent to prison received 42 months or more, and a quarter received 10.5 months or less. The yearly table shows medians from 11 months in 2023 to 60 months in 2016 and 2022\. Those years each have 1 or 2 people, so the swings should not be read as trends. | Fiscal year | People sentenced | Median prison | Pleaded guilty | | ----------- | ---------------- | ------------- | -------------- | | 2016 | 1 | 60 months | 1 of 1 | | 2017 | 2 | 28 months | 2 of 2 | | 2018 | 6 | 15 months | 6 of 6 | | 2019 | 3 | 20 months | 3 of 3 | | 2021 | 2 | n/a | 2 of 2 | | 2022 | 1 | 60 months | 1 of 1 | | 2023 | 2 | 11 months | 2 of 2 | ## Pleas and Plea Agreements All 17 people (100%) pleaded guilty, and 100% of the guilty pleas had a written plea agreement. No one was convicted after a trial. There are no straight pleas in this group. No mandatory minimum prison term applied to any case. A mandatory minimum is a shortest prison term set by statute, and none was recorded for these people. Pleas were also uniform, so the plea route did not separate one group of cases from another. ## Sentences Below the Guideline Range Only 5 sentences (29%) were within the guideline range. Another 4 (24%) were below the range at the government's request. A larger group, 8 sentences (47%), were below the range without a government request. None was above the range. The most common position was therefore below the range without a government request. The records do not give a reason for any individual sentence. ## Supervised Release and Criminal History Supervised release after prison was ordered for 14 people (82%), with a median term of 36 months. In criminal history, 88% were in the lowest category I and 0% in the highest (VI). ## Earlier Years Versus Later Years Fiscal years 2016 to 2019 had 12 people and a median prison term of 18 months. Fiscal years 2020 to 2025 had 5 people and a median of 14 months. The later group is smaller, and the table shows no cases in fiscal year 2020. The records cannot show whether the change in count reflects fewer cases, different charging choices, or something else. ## What the Records Do Not Cover Only people who were convicted and sentenced appear. Acquittals and dismissals do not. Prison terms are terms imposed, not time served. The crosswalk lists no close court-martial counterpart for this guideline. ### How We Counted Everyone sentenced in federal court in fiscal years 2016 to 2025 whose primary sentencing guideline was §2T2.1 (17), 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. ## 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) - [§2T1.4 Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2t1-4-aiding-assisting-procuring-counseling-or-advising-tax/) (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.