District Sentencing

Guidelines Manual, Chapter TwoFY2018–FY2025

Guidelines

§2T1.4

Aiding, assisting or advising tax fraud · 0.2% of federal cases · Guidelines Manual

The datafile contains cases reported to the Commission with sentencing documents. Sentence length statistics use the Commission's capped variable (sentences of 470 months or longer, including life, are recorded as 470 months) and exclude sentences of probation or a fine only. Figures are aggregates of past cases and are not a prediction for any case.

112cases, FY20251,109 over FY2018–FY2025
21median prison monthsall cases 24
23%within guideline rangeall cases 47%
70%cases with a prison termall cases 92%

§ 1Length of prison terms

12%
10%
30%
22%
17%
8%
1%
<10
median 21 mo
under 6 mo6–11 mo1–2 yr2–3 yr3–5 yr5–10 yr10–15 yr15–20 yr20–30 yr30 yr+life
Share of cases with a prison term, by length of the term (781 cases with a prison term; life and terms of 470 months or more counted as life). Grey: all federal cases.

Interquartile range 12–36 months; mean 27. 0 cases at the 470-month cap.

§ 2Summary

§2T1.4 (aiding, assisting or advising tax fraud) was the primary guideline in 1,109 cases sentenced across 8 fiscal years (FY2018–FY2025), 0.2% of all cases, with 112 in FY2025. The Commission classes most of them as tax.

The median prison term under §2T1.4 was 21 months (1 yr 9 mo) (all cases nationally: 24 months); 70% of cases carried a prison term.

23% of sentences were within the guideline range. Of the rest, 27% were below the range on a government motion, 48% below it for other reasons and 1% above it. The departure and variance table below uses the Commission's nine SENTRNGE categories.

FY2025 had fewer cases than FY2018 (112 against 195). The median prison term was about the same in FY2025 as in FY2018.

§ 3Departures and variances

Within guideline range 23%Above range 1%Below range, government sponsored 27%Below range, other 48%Not determinable 0

Commission category (SENTRNGE)CasesShareAll cases
Within range25923.4%47.4%
Upward departure<10—0.5%
Above-range variance121.1%2.6%
§5K1.1 substantial assistance16815.1%9.5%
§5K3.1 early disposition<10—9.2%
Government-sponsored departure131.2%1.9%
Government-sponsored variance11810.6%8.0%
Downward departure252.3%2.1%
Below-range variance51246.2%18.8%
Missing or indeterminable0——

Shares are of cases with a determinable range status. Departures cite a provision of the Guidelines Manual; variances rest on the statutory sentencing factors (18 U.S.C. §3553(a)) after United States v. Booker.

§ 4Cases by fiscal year

195
166
121
138
139
126
112
112
’18’19’20’21’22’23’24’25
Cases sentenced under §2T1.4 per fiscal year (fiscal years 2018–2025)
24
18
22
18
20
24
21
24
’18’19’20’21’22’23’24’25
Median prison months by fiscal year (fiscal years 2018–2025)
Fiscal yearCasesPrisonMedian monthsWithin rangeBelow, gov.Below, otherAbove
FY201819572%2428%26%45%—
FY201916674%1822%24%54%—
FY202012173%2226%26%48%0%
FY202113864%1823%21%57%0%
FY202213965%2019%34%47%—
FY202312669%2418%32%48%—
FY202411273%2128%21%49%—
FY202511274%2423%36%39%—

§ 5Offence types the Commission assigns

Primary offence typeCasesShare
Tax1,109100.0%

§ 6Districts with the most cases

DistrictCasesPrisonMedian monthsWithin rangeBelow, gov.Below, other
Southern District of Florida S.D. Fla.55—2842%20%36%
Middle District of Florida M.D. Fla.53—3332%26%40%
Northern District of Texas N.D. Tex.51—3635%29%29%
Eastern District of Pennsylvania E.D. Pa.42—2424%33%43%
Central District of California C.D. Cal.4166%15—27%46%
Southern District of Texas S.D. Tex.38—14——55%
Western District of Texas W.D. Tex.3453%24——56%
District of New Jersey D.N.J.3266%24—41%38%
District of Massachusetts D. Mass.2966%12——52%
Eastern District of New York E.D.N.Y.2748%15——56%
Western District of North Carolina W.D.N.C.2756%24——59%
Northern District of Illinois N.D. Ill.27—14——82%
Southern District of New York S.D.N.Y.25—4——68%
Western District of Pennsylvania W.D. Pa.2548%15—48%—
District of South Carolina D.S.C.24—24——63%
Eastern District of Virginia E.D. Va.24—26——54%
District of Connecticut D. Conn.23—10——78%
Southern District of Ohio S.D. Ohio23—12——52%
Northern District of Ohio N.D. Ohio21—18——48%
Eastern District of Missouri E.D. Mo.21—36——52%

By circuit

CircuitCasesPrisonMedian monthsWithin rangeBelow, gov.Below, other
District of Columbia Circuit<10fewer than 10 cases
First Circuit3263%12——50%
Second Circuit8858%12—28%63%
Third Circuit11172%2423%38%40%
Fourth Circuit13276%2424%27%50%
Fifth Circuit17977%2430%26%40%
Sixth Circuit8659%1222%22%56%
Seventh Circuit6769%15—18%72%
Eighth Circuit6659%2423%20%58%
Ninth Circuit14062%1219%34%45%
Tenth Circuit25—18——40%
Eleventh Circuit17984%2534%24%42%

§ 7Questions and answers

What is §2T1.4?

Section 2T1.4 of the Guidelines Manual: aiding, assisting or advising tax fraud. On this site a case is counted under a guideline when the Commission records it as the primary guideline (GDLINEHI) applied at sentencing.

What is the typical sentence under §2T1.4?

The median prison term over FY2018–FY2025 was 21 months (1 yr 9 mo), with the middle half between 12 and 36 months.

How often do sentences under §2T1.4 depart or vary from the range?

77% of sentences were outside the guideline range. Substantial-assistance motions under §5K1.1 accounted for 15% and below-range variances for 46%.

Which districts see the most §2T1.4 cases?

the Southern District of Florida (55), the Middle District of Florida (53) and the Northern District of Texas (51).

§ 8Provenance

Source: United States Sentencing Commission, Individual Offender Datafiles, fiscal years 2018–2025 (US government works), aggregated by this site; the FY2025 file is dated 29 Apr 2026. Guideline is the Commission's GDLINEHI field (primary guideline applied). Counts below 10 are hidden or pooled. Errors in this site's processing are corrected at the next build; see corrections. Methodology.