Any person required under this title to pay any estimated tax or tax, or required by this title or by regulations made under authority thereof to make a return, keep any records, or supply any information, who willfully fails to pay such estimated tax or tax, make such return, keep such records, or supply such information, at the time or times required by law or regulations, shall, in addition to other penalties provided by law, be guilty of a misdemeanor and, upon conviction thereof, shall be fined not more than $25,000 ($100,000 in the case of a corporation), or imprisoned not more than 1 year, or both, together with the costs of prosecution. In the case of any person with respect to whom there is a failure to pay any estimated tax, this section shall not apply to such person with respect to such failure if there is no addition to tax under section 6654 or 6655 with respect to such failure. In the case of a willful violation of any provision of section 6050I, the first sentence of this section shall be applied by substituting “felony” for “misdemeanor” and “5 years” for “1 year”.
Notes of Decisions
Cited in
1,423
cases (
46 in the last 5 years), 1957–2026 · leading case:
United States v. Snipes, 611 F.3d 855 (11th Cir. 2010).
United States v. Snipes, 611 F.3d 855 (11th Cir. 2010).
· cites it 6× “MARCUS, Circuit Judge: Defendant Wesley Trent Snipes appeals from his criminal convictions, after a jury trial, on three counts of willful failure to file individual federal income tax returns for calendar years 1999, 2000, and 2001, in violation of 26 U.S.C. § 7203 . Snipes…”
Garner v. United States, 424 U.S. 648 (1976).
· cites it 6× “First, the Service could have sought to have Garner criminally prosecuted under § 7203 of the Internal Revenue Code of 1954 (Code), 26 U. S. C. § 7203 , which proscribes, among other things, the willful failure to make a return.”
Cheek v. United States, 498 U.S. 192 (1991).
· cites it 4× “Under 26 U. S. C. § 7203 , "[a]ny person required under this title .”
In Re Complaint as to the Conduct of Lawrence, 31 P.3d 1078 (Or. 2001).
· cites it 13× “The federal statute, 26 USC § 7203 , provides, in part: “Any person required under this title to pay any estimated tax or tax, or required by this title or by regulations made under authority thereof to make a return, keep any records, or supply any information, who willfully…”
United States v. Clayton, 506 F.3d 405 (5th Cir. 2007).
· cites it 8× “§ 7206 (1) and six counts of willful failure to file a tax return in violation of 26 U.S.C. § 7203 . Clayton appeals his conviction on the six counts of willful failure to file a tax return, arguing that the Internal Revenue Code and tax regulations do not contain a valid…”
United States v. United States Coin & Currency, 401 U.S. 715 (1971).
· cites it 6× “[3] *740 Of course, the case before us does not involve the legislative repeal of an existing criminal statute but a construction of the Fifth Amendment by this Court contrary to past interpretations of that amendment and having the effect of barring enforcement of 26 U. S. C. §…”
United States v. Ruth Studley, 783 F.2d 934 (9th Cir. 1986).
· cites it 3× “1 26 U.S.C. § 7203 . Studley filed a timely notice of appeal and raises a host of issues before us.”
United States v. Hassebrock, 663 F.3d 906 (7th Cir. 2011).
· cites it 4× “§ 7201 , and failure to file a tax return for the 2004 tax year, a misdemeanor offense under 26 U.S.C. § 7203 . He appeals the district court’s denial of his motions for a judgment of acquittal and for a new trial.”
United States v. Josephberg, 562 F.3d 478 (2d Cir. 2009).
· cites it 4× “§ 7206 (1) (Counts 5 and 6); willful failure to file timely personal income tax returns for the years 1999-2002, in violation of 26 U.S.C. § 7203 (Counts 7-10); willful failure to pay income tax due for the years 1999-2003, in violation of 26 U.”
United States v. John Rankin, 929 F.3d 399 (6th Cir. 2019).
· cites it 4× “Lesser-included offense instruction Second, Rankin argues that the district court should have instructed the jury on his proposed lesser-included offense under 26 U.S.C. § 7203 along with the actually charged greater offense under 26 U.”
United States v. Roy Bradley, Sr., 917 F.3d 493 (6th Cir. 2019).
· cites it 3× “Prior to trial, Bradley submitted a motion in limine requesting that the jury be instructed on the proposed lesser-included offenses of conspiracy to fail to file W-2s or issue 1099s, in violation of 26 U.S.C. §§ 7203 and 7204, respectively.”
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