26 U.S.C. 7206, Fraud and false statements: How Federal Cases Ended, FY2016–2025
In fiscal years 2016 to 2025, 1,828 of 1,890 federal defendants (97%) whose most serious final charge was under 26 U.S.C. 7206 were convicted. Of those convicted, 1,097 (60%) were sentenced to prison on that charge, with a median term of 15 months. Only 73 cases went to trial, and 6 of those ended i
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In brief: In fiscal years 2016 to 2025, 1,828 of 1,890 federal defendants (97%) whose most serious final charge was under 26 U.S.C. 7206 were convicted. Of those convicted, 1,097 (60%) were sentenced to prison on that charge, with a median term of 15 months. Only 73 cases went to trial, and 6 of those ended in an acquittal (8%).
This post uses the Federal Judicial Center's records of 1,890 federal defendants whose cases ended in fiscal years 2016 to 2025. The series also draws on the U.S. Sentencing Commission's records of 659,036 people sentenced 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.
Convictions and Prison Sentences
The conviction count of 1,828 includes guilty pleas and guilty verdicts at trial. It equals 97% of every defendant counted under this section.
A prison term on this charge followed for 1,097 of the convicted defendants (60%). The other convicted defendants had no prison term recorded on this charge.
For defendants with a term of 1 month or more, the median prison term was 15 months. That is the middle value of the terms when sorted by length. Time on any other count is outside this figure.
Which Section Is This?
Title 26, section 7206 of the U.S. Code has the heading "Fraud and false statements". The post names the statute by that heading only.
The Federal Judicial Center records, counted as in the federal courts' Table D-4, list 1,890 defendants with this section as the most serious charge at the end of the case. The count takes in every way a case can end, including dismissal and acquittal.
All 1,890 were charged at the felony level. None was recorded as a Class A misdemeanor or a petty offense.
How the Cases Closed
A guilty plea closed 1,761 cases (93%). A dismissal closed 56 (3%). A trial closed 73 (4%).
The records treat a charge dropped on the government's motion as a dismissal. That can happen after a defendant pleads guilty in another case, so a dismissal does not prove the person avoided conviction.
Juries heard 67 of the trials and acquitted in 4 (6%). Of the 6 bench trials, which a judge decides without a jury, 2 ended in an acquittal.
Lawyers Recorded at the End of the Case
Retained private counsel represented 1,277 defendants (68%). Federal public or community defenders represented 353 (19%). CJA panel attorneys, private lawyers appointed by the court, represented 231 (12%). Only 3 defendants had no lawyer.
Federal defenders and retained counsel each had a 95% guilty plea rate. CJA panel attorneys had a 90% rate. At trial, federal defenders had 15 trials and no acquittals. CJA panel attorneys had 17 trials with 2 acquittals (12%), and retained counsel had 40 trials with 4 acquittals (10%).
No ranking of lawyers follows from these numbers. They describe groups of cases, not lawyer quality. Counsel type is set at the end of the case, and people with hired lawyers often face different charges and circumstances than people with appointed lawyers.
| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| Federal public or community defender | 353 | 95% | 1% | 15 | 0 (0%) |
| CJA panel attorney | 231 | 90% | 3% | 17 | 2 (12%) |
| Private (retained) counsel | 1,277 | 95% | 2% | 40 | 4 (10%) |
| Self-represented | 3 | 2 of 3 | 0 of 3 | 1 | 0 (0 of 1) |
Cases Ended Each Fiscal Year
The number of cases ending each year was higher early in the period. Fiscal year 2016 had 232, and fiscal year 2025 had 151.
Guilty plea rates stayed between 90% and 97% every year. Fiscal year 2019 had 3 acquittals in 10 trials (30%), the most of any year. Fiscal year 2020 had only 2 trials. Small yearly trial counts like these do not form a trend.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 232 | 93% | 3% | 10 | 1 (10%) |
| 2017 | 219 | 93% | 3% | 9 | 0 (0 of 9) |
| 2018 | 226 | 92% | 3% | 12 | 1 (8%) |
| 2019 | 207 | 93% | 2% | 10 | 3 (30%) |
| 2020 | 160 | 97% | 2% | 2 | 0 (0 of 2) |
| 2021 | 190 | 95% | 2% | 6 | 0 (0 of 6) |
| 2022 | 179 | 92% | 4% | 6 | 0 (0 of 6) |
| 2023 | 165 | 90% | 4% | 10 | 1 (10%) |
| 2024 | 161 | 94% | 4% | 4 | 0 (0 of 4) |
| 2025 | 151 | 95% | 3% | 4 | 0 (0 of 4) |
Questions the Data Cannot Answer
The approved crosswalk includes no close court-martial counterpart for this section, so the numbers are federal only. The records hold no details about the conduct in any case. They cannot show why yearly counts fell, why charges were dismissed, or whether the type of lawyer changed how any case ended.
How We Counted
Every federal defendant whose case ended in fiscal years 2016 to 2025 and whose most serious charge at the end of the case (TTITLE1) was under 26 U.S.C. 7206, any subsection (1,890), Federal Judicial Center, counted as in the federal courts' Table D-4. Type of counsel is TCOUNSEL; labels from the FJC criminal codebook. Section heading from the U.S. Code as published by the Office of the Law Revision Counsel (release point 119-136).
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
Who is in each set of numbers. The federal sentencing numbers come from the U.S. Sentencing Commission. They count only people who were convicted and sentenced in federal district court. People whose cases were dismissed or who were acquitted are not in them. The military numbers come from court-martial results, which include acquittals. To compare acquittal or dismissal rates, the federal side uses a different source: the Federal Judicial Center's case data, which counts every defendant whose case ended.
How "plea" and "trial" are counted. In the federal sentencing numbers, "trial" means the person was convicted after a trial, including people who pleaded guilty to some counts and went to trial on others. People acquitted at trial are not in these numbers at all (see "Who is in each set of numbers"). In the federal case data, the trial rate counts both convictions and acquittals at trial among all defendants whose cases ended, including dismissed cases. Military numbers count contested cases that reached a verdict. These denominators are not the same, and each post states the one it uses.
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.
Type of counsel describes groups of cases, not lawyers. The Federal Judicial Center records the type of counsel at the end of the case. Defendants who hire a lawyer differ from defendants who receive an appointed lawyer in their charges, criminal history, and circumstances, and some defendants change lawyers during a case. Differences in outcomes by type of counsel therefore cannot be credited to the type of lawyer.
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)
- 26 U.S.C. 7202, Willful failure to collect or pay over tax: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 26 U.S.C. 7203, Willful failure to file return, supply information, or pay tax: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 26 U.S.C. 7212, Attempts to interfere with administration of internal revenue laws: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- Appointed vs. Retained Lawyers in Federal Criminal Cases: How Cases Ended, 2016–2025
- Are Courts-Martial More Likely to End in Acquittal Than Federal Trials?
- 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.