§7212 — Attempts to interfere with administration of internal revenue laws

34 cases·6 followed·2 distinguished·1 limited·9 overruled·16 cited18% support

(a)Corrupt or forcible interference

Whoever corruptly or by force or threats of force (including any threatening letter or communication) endeavors to intimidate or impede any officer or employee of the United States acting in an official capacity under this title, or in any other way corruptly or by force or threats of force (including any threatening letter or communication) obstructs or impedes, or endeavors to obstruct or impede, the due administration of this title, shall, upon conviction thereof, be fined not more than $5,000, or imprisoned not more than 3 years, or both, except that if the offense is committed only by threats of force, the person convicted thereof shall be fined not more than $3,000, or imprisoned not more than 1 year, or both. The term “threats of force”, as used in this subsection, means threats of bodily harm to the officer or employee of the United States or to a member of his family.

(b)Forcible rescue of seized property

Any person who forcibly rescues or causes to be rescued any property after it shall have been seized under this title, or shall attempt or endeavor so to do, shall, excepting in cases otherwise provided for, for every such offense, be fined not more than $500, or not more than double the value of the property so rescued, whichever is the greater, or be imprisoned not more than 2 years.

34 Citing Cases

Daniel Metz, Petitioner T.C. Memo. 2022-33 · 2022

ourt for the Middle District of Florida indicted petitioner on three counts of filing false or fraudulent claims for 2005, 2006, and 2007 under 18 U.S.C. § 287 and one count of attempting to obstruct or interfere with the Internal Revenue Laws under section 7212. Petitioner pleaded not guilty, but he was ultimately convicted by a jury on all counts on July 18, 2013. On December 20, 2013, the District Court entered judgment against petitioner, and he was sentenced to 30 months in a federal penite

. In a superseding indictment, petitioner was charged with subscribing to false income tax returns under section 7206(1) for - 17 - [*17] 2004 through 2008.8 Petitioner was also charged with impeding administration ofthe internal revenue laws under section 7212. After ajury trial, petitioner was convicted ofall charges in the superseding indictment and sentenced to a 27-month prison term. Petitioner appealed his conviction to the U.S. Court ofAppeals for the Eighth Circuit. The Court of Appeals

. In a superseding indictment, petitioner was charged with subscribing to false income tax returns under section 7206(1) for - 17 - [*17] 2004 through 2008.8 Petitioner was also charged with impeding administration ofthe internal revenue laws under section 7212. After ajury trial, petitioner was convicted ofall charges in the superseding indictment and sentenced to a 27-month prison term. Petitioner appealed his conviction to the U.S. Court ofAppeals for the Eighth Circuit. The Court of Appeals

Kohn pleaded guilty to and was convicted ofone count ofviolating section 7212 for obstructing the administration ofthe internal revenue laws by creating fictitious debenture transactions to reduce clients' Federal income tax and crafting fee arrangements based on tax reduction.

Respondent also invites our attention to the caption ofsection 7212, "Attempts to Interfere with Administration ofInternal Revenue Laws", and points out that subsection (a) ofsection 7212 makes it a crime to block an official acting "under this title".

Respondent also invites our attention to the caption ofsection 7212, "Attempts to Interfere with Administration ofInternal Revenue Laws", and points out that subsection (a) ofsection 7212 makes it a crime to block an official acting "under this title".

preparing and filing false and raudulent Federal income·tax returns- for himself and clieÅts in violation of section 7212 (a) ; (2) eight counts.

preparing and filing false and raudulent Federal income·tax returns- for himself and clieÅts in violation of section 7212 (a) ; (2) eight counts.

Respondent also .relied on petitioner's plea under section 7212 to argue that petitioner had fraudulent intent .

Michael E. & Catherine K. Kohn, Petitioner T.C. Memo. 2009-117 · 2009

Kohn-pleaded guilty to one count of attempting to interfere with the administration of internal revenue laws,:in violation of section 7212 .3 From November 2002 to May 2003 Mr .

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