18 U.S.C. § 3284
Concealment of bankrupt’s assets
The concealment of assets of a debtor in a case under title 11 shall be deemed to be a continuing offense until the debtor shall have been finally discharged or a discharge denied, and the period of limitations shall not begin to run until such final discharge or denial of discharge.
Notes of Decisions
Cited in 51
cases (3 in the last 5 years), 1957–2026 · leading case: United States v. Robert E. Brennan, 326 F.3d 176 (3rd Cir. 2003).
United States v. Robert E. Brennan, 326 F.3d 176 (3rd Cir. 2003). “See 18 U.S.C. § 3284 (“concealment of assets of a debtor .”
United States v. Sunia, 643 F. Supp. 2d 51 (D.D.C. 2009). “The government correctly states that in Stein the First Circuit concluded that bankruptcy fraud is a continuing offense; however, that conclusion turned in large part on the fact that Congress explicitly stated as much in 18 U.S.C. § 3284 . Stein, 233 F.3d at 18 -19 & n.”
United States v. Gary L. Dolan, 120 F.3d 856 (8th Cir. 1997). “Dolan argues that the statute of limitations that pertains to concealment of bankruptcy assets and treats concealment as a continuing offense, 18 U.S.C. § 3284 , does not apply to the case at bar because Anderson did not seek a discharge from bankruptcy and was not discharged or…”
United States v. David R. Knoll & Ted W. Gleave, 16 F.3d 1313 (2d Cir. 1994). “” The trial court ruled the statute of limitations bar with respect to count four was overcome by 18 U.S.C. § 3284 (1988). See Gleave, 786 F.”
In Re May, 12 B.R. 618 (N.D. Fla. 1980). “17[2], Title 18 U.S.C. § 3284 provides specifically that concealments shall be deemed to be continuing offenses and that the statute of limitations in a concealment case does not begin to run until there has been either a discharge or a denial of discharge.”
United States v. Gilbert, 136 F.3d 1451 (11th Cir. 1998). “” 18 U.S.C. § 3284 (emphasis added). So, not only has Congress expressed that concealment is a continuing offense, Congress has also specified when that continuing offense shall be deemed complete for limitations purposes.”
Duncan v. State, 384 A.2d 456 (Md. 1978). “18 U.S.C. § 3284 (1948) provided: "The concealment of assets of a bankrupt or other debtor shall be deemed to be a continuing offense until the debtor shall have been finally discharged or a discharge denied, and the period of limitations shall not begin to run until such final…”
United States v. Santos Hernan Rivera-Ventura, 72 F.3d 277 (2d Cir. 1995). “, 18 U.S.C. § 3284 (1994) (concealment of bankrupt’s assets “shall be deemed to be a continuing offense” until date of final bankruptcy discharge); or by, instead of the phrase “is at any time found in,” using a phrase such as “remains in,” see, e.”
State v. Valdiviezo-Martinez, 486 P.3d 1256 (Kan. 2021). “Here, neither the 2005 nor the 2012 version of the identity theft statute explicitly states it is an ongoing crime. See K.S.A. 2003 Supp. 21-4018(a); K.”
United States v. Dunne, 324 F.3d 1158 (10th Cir. 2003). “, 18 U.S.C. § 3284 (“The concealment of assets of a debtor” in a Chapter 11 case “shall be deemed to be a continuing offense” until the date of final bankruptcy discharge).”
United States v. Stein, 233 F.3d 6 (1st Cir. 2000). “We do not find clear error in the district courts refusal to subtract Golen-bock and Steins annual payments from the $74,000. Nor is there error in the fact that the court evaluated the intended loss at the time Golenbock and Stein sold the Well-fleet property, rather than at…”
United States v. Robert Morales, Sr., 11 F.3d 915 (9th Cir. 1993). “Examples of such statutes are 18 U.S.C. § 3284 , which says that concealment of a bankrupt’s assets “shall be deemed a continuing offense” up until the grant or denial of the final bankruptcy discharge, see United States v.”
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