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United States v. Delfino

510 F.3d 468 (2007)

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United States v. Delfino

United States Court of Appeals for the Fourth Circuit
510 F.3d 468 (2007)

Facts

James and Jeaniene Delfino (defendants) did not file tax returns for 1993 through 2004. Additionally, the Delfinos assigned their incomes to trusts that failed to file returns or pay taxes. The Delfinos refused to cooperate with an audit conducted by the Internal Revenue Service (IRS). Accordingly, the IRS assessed taxes against the Delfinos based on bank records. In doing so, the IRS did not include deductions to which the Delfinos would have been entitled. The Delfinos were convicted of numerous criminal charges. At sentencing, the Delfinos contended that the United States’ tax loss due to their crimes should be reduced to reflect deductions that they could have claimed. The district court disagreed and, pursuant to United States Sentencing Guideline (USSG) § 2T1.1(c)(1), sentenced the Delfinos based on the tax loss that the IRS assessed. The Delfinos appealed, claiming that deductions had to be included in the tax-loss calculation pursuant to (1) the United States Court of Appeals for the Fourth Circuit’s decision in United States v. Schmidt and (2) USSG § 2T1.1(c)(2)(A).

Rule of Law

Issue

Holding and Reasoning (Shedd, J.)

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Casebooks

Tax Practice and Procedure

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