Federal Tax Offense Sentences in the Middle District of Tennessee, FY2016–2025
Of 24 people sentenced for tax offenses in the Middle District of Tennessee in fiscal years 2016 to 2025, 3 (13%) received a sentence within the guideline range. 17 (71%) were sent to prison, and the median prison term was 12 months. Nationally, 66% were sent to prison and the median was 15.1 months
Understanding Trends in Military Practice · 7 min read
Trends › Federal Prosecution Analysis › Federal Sentences in the Middle District of Tennessee, FY201 › Tax Offense: Middle District of Tennessee
In brief: Of 24 people sentenced for tax offenses in the Middle District of Tennessee in fiscal years 2016 to 2025, 3 (13%) received a sentence within the guideline range. 17 (71%) were sent to prison, and the median prison term was 12 months. Nationally, 66% were sent to prison and the median was 15.1 months.
This post uses the U.S. Sentencing Commission's records of 24 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 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.
Sentences Mostly Fell Below the Guideline Range
The U.S. Sentencing Commission had position-against-the-range information for all 24 people in this group. 3 (13%) were sentenced within the guideline range. 6 (25%) were sentenced below the range at the government's request, and 15 (63%) were sentenced below the range without a government request. None was sentenced above the range.
Across all 94 federal districts, 24% of tax sentences were within the guideline range. In the Middle District of Tennessee, all offenses together had 26% within the range. Tax sentences here were within the range less often than either figure.
A sentence below the range without a government request means the court chose the lower sentence on its own. The data does not show the reasons.
Prison, Probation, and Median Terms
Tax cases were less than 1% of the 2,879 people sentenced in the district during these years. 17 of the 24 (71%) received a prison term, and 5 (21%) received probation only, with no prison or other confinement.
Among those sent to prison, the median prison term was 12 months. A quarter received 18 months or more, and a quarter received 6 months or less. For all 94 districts, 66% of tax defendants were sent to prison and the median term was 15.1 months.
For all offenses in this district, the median prison term was 50 months. Tax terms were much shorter than that district-wide figure, and the tax group and the district cover different mixes of offenses.
Which Tax Guidelines Applied
The Commission's offense type "Tax" is a category, not one statute. The most common primary guideline here was §2T1.4 (Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud), with 12 people.
Next was §2T1.1 (Tax Evasion), with 10 people, followed by §2T1.6 (Failing to Collect or Truthfully Account for and Pay Over Tax), with 2 people.
Pleas, Trials, and Plea Agreements
23 of the 24 people (96%) pleaded guilty, and 1 person was convicted after a trial. The national rate of guilty pleas for tax cases was 93%, and the district's rate for all offenses was 96%.
The median prison term was 11 months after a guilty plea. For the 1 person convicted at trial and sent to prison, the term was 24 months. One person cannot show a pattern.
Among the guilty pleas, 91% had a written plea agreement, and 9% were straight pleas with no agreement. No mandatory minimum applied to any of the 24 people.
Supervised Release, Fines, and Restitution
16 people (67%) were ordered to serve supervised release after prison, with a median term of 18 months. A fine was ordered for 4 people (17%). Restitution was ordered for 23 (96%).
Criminal history was low. 88% were in the lowest category and 0% were in the highest category. Court-martial records have no criminal history field.
Yearly Counts
Fiscal years 2016 to 2019 had 11 people, and fiscal years 2020 to 2025 had 13. The yearly counts range from 1 to 7. Fiscal year 2024 had the most, with 7 people, of whom 6 pleaded guilty.
With counts this small, the yearly medians in the table reflect only a few people each and do not show a trend.
| Fiscal year | People sentenced | Median prison | Pleaded guilty |
|---|---|---|---|
| 2016 | 2 | 18 months | 2 of 2 |
| 2017 | 5 | 12 months | 5 of 5 |
| 2018 | 3 | 4 months | 3 of 3 |
| 2019 | 1 | 12 months | 1 of 1 |
| 2021 | 2 | 12 months | 2 of 2 |
| 2022 | 1 | 10 months | 1 of 1 |
| 2023 | 1 | 6 months | 1 of 1 |
| 2024 | 7 | 12 months | 6 of 7 |
| 2025 | 2 | 12 months | 2 of 2 |
Limits of the Records
The data counts only people who were convicted and sentenced. Acquittals and dismissals are not included, and prison terms are those imposed, not time served. The records do not give the amount of tax involved or the reasons for any sentence below the range.
How We Counted
Everyone sentenced in federal court in the Middle District of Tennessee (U.S. Sentencing Commission district label "Tennessee Mid") in fiscal years 2016 to 2025 whose offense type was "Tax" (24). Offense types are the Commission's OFFGUIDE categories.
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)
- Federal Sentences in the Middle District of Tennessee, FY2016–2025 (overview)
- Federal Firearms Sentences in the Middle District of Tennessee, FY2016–2025 (same district, other offense type)
- Federal Drug Trafficking Sentences in the Middle District of Tennessee, FY2016–2025 (same district, other offense type)
- Federal Fraud, Theft, and Embezzlement Sentences in the Middle District of Tennessee, FY2016–2025 (same district, other offense type)
- Federal Immigration Offense Sentences in the Middle District of Tennessee, FY2016–2025 (same district, other offense type)
- 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.