26 U.S.C. 7212, Attempts to interfere with administration of internal revenue laws: How Federal Cases Ended, FY2016–2025
Of 137 federal defendants whose most serious final charge was under 26 U.S.C. 7212, 19 (14%) went to trial in fiscal years 2016 to 2025, and 2 of those trials ended in an acquittal. Guilty pleas ended 111 cases (81%), and 128 defendants (93%) were convicted. Of those convicted, 96 (75%) received a p
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Trends › Federal Prosecution Analysis › 26 U.S.C. 7212
In brief: Of 137 federal defendants whose most serious final charge was under 26 U.S.C. 7212, 19 (14%) went to trial in fiscal years 2016 to 2025, and 2 of those trials ended in an acquittal. Guilty pleas ended 111 cases (81%), and 128 defendants (93%) were convicted. Of those convicted, 96 (75%) received a prison term on that charge, with a median of 18 months.
This post uses the Federal Judicial Center's records of 137 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.
Trials Under Section 7212
Trials ended 19 of the 137 cases. Juries decided 18 of them and acquitted in 1 (6%). A judge decided the only bench trial, and it ended in an acquittal.
Across all 19 trials, 2 ended in an acquittal (11%). With only 19 trials over the period, each verdict changes that rate a great deal.
Heading, Count, and Charge Level
The U.S. Code heads Title 26, section 7212 as "Attempts to interfere with administration of internal revenue laws". That heading is the only description of the statute used here.
The Federal Judicial Center counted 137 defendants whose most serious charge at the end of the case fell under this section, as in the federal courts' Table D-4. Dismissals and acquittals are part of the count.
Felonies made up 135 of the charges (99%). The other 2 (1%) were Class A misdemeanors, and none was a petty offense.
Pleas, Dismissals, and Sentences
Guilty pleas ended 111 cases, and 7 (5%) were dismissed. A dismissal in these records can include a charge the government dropped after a guilty plea in another case.
Of the 128 convicted, 96 (75%) received a prison term on this charge. For terms of 1 month or more, the median was 18 months, the middle value when the terms are ordered. Terms on other counts are not part of it.
Representation by Type of Counsel
Retained counsel represented 90 defendants (66%). Federal public or community defenders represented 28 (20%), and CJA panel attorneys, private lawyers appointed by the court, represented 17 (12%).
The guilty plea rate was 96% for federal defenders, 81% for retained counsel, and 65% for CJA panel attorneys. Retained counsel went to trial 13 times, and both acquittals came in that group (15%). CJA panel attorneys had 5 trials and federal defenders had 1, with no acquittals.
The groups are small, and they describe groups of cases, not the quality of lawyers. Counsel type is recorded at the end of the case. Defendants who hire a lawyer and those who are appointed one face different charges and circumstances.
| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| Federal public or community defender | 28 | 96% | 0% | 1 | 0 (0 of 1) |
| CJA panel attorney | 17 | 65% | 6% | 5 | 0 (0 of 5) |
| Private (retained) counsel | 90 | 81% | 4% | 13 | 2 (15%) |
Counts by Fiscal Year
Fiscal year 2017 had the most cases end, at 31. From fiscal year 2021 through 2025, no year had more than 11. Yearly counts this small cannot show a trend.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 21 | 81% | 10% | 2 | 0 (0 of 2) |
| 2017 | 31 | 87% | 3% | 3 | 0 (0 of 3) |
| 2018 | 22 | 73% | 5% | 5 | 0 (0 of 5) |
| 2019 | 12 | 75% | 0% | 3 | 1 (1 of 3) |
| 2020 | 13 | 69% | 8% | 3 | 0 (0 of 3) |
| 2021 | 5 | 4 of 5 | 0 of 5 | 1 | 0 (0 of 1) |
| 2022 | 8 | 7 of 8 | 0 of 8 | 1 | 1 (1 of 1) |
| 2023 | 11 | 91% | 9% | 0 | 0 |
| 2024 | 7 | 6 of 7 | 0 of 7 | 1 | 0 (0 of 1) |
| 2025 | 7 | 6 of 7 | 1 of 7 | 0 | 0 |
Outside the Scope of These Records
The approved crosswalk shows no close court-martial counterpart for this section, so only federal numbers appear. The records do not describe the conduct, the evidence, or the reasons for any dismissal or verdict.
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. 7212, any subsection (137), 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. 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. 7206, Fraud and false statements: 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.