Unclaimed Deductions at Criminal Tax Sentencing

Washington, D.C. partner Joseph Rillotta and associate Alison Agnew authored “Criminal Tax Sentencing,” which was published in the July 10 edition of TaxNotes.

In 2013, the U.S. Sentencing Commission amended Sentencing Guidelines Section 2T1.1 to direct trial court judges, in certain circumstances, to consider deductions and credits not previously claimed by defendants on their tax returns when calculating defendants’ tax loss for purposes of determining their Sentencing Guidelines range. Joe and Alison examine the impact of this amendment on criminal tax sentencings.