U.S. Code » Title 26 » Subtitle Subtitle F— Procedure and Administration › Chapter CHAPTER 75— CRIMES, OTHER OFFENSES, AND FORFEITURES › Subchapter Subchapter A— Crimes › Part PART I— GENERAL PROVISIONS

26 U.S.C. § 7207

Fraudulent returns, statements, or other documents

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Any person who willfully delivers or discloses to the Secretary any list, return, account, statement, or other document, known by him to be fraudulent or to be false as to any material matter, shall be fined not more than $10,000 ($50,000 in the case of a corporation), or imprisoned not more than 1 year, or both. Any person required pursuant to section 6047(b), section 6104(d), or subsection (i) or (j) of section 527 to furnish any information to the Secretary or any other person who willfully furnishes to the Secretary or such other person any information known by him to be fraudulent or to be false as to any material matter shall be fined not more than $10,000 ($50,000 in the case of a corporation), or imprisoned not more than 1 year, or both.

Notes of Decisions
Cited in 79 cases, 1956–2020 · leading case: Schmuck v. United States, 489 U.S. 705 (1989).
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Schmuck v. United States, 489 U.S. 705 (1989). · cites it 2× “343, 352 (1965) (analyzing the elements involved in 26 U. S. C. § 7207 , and finding that they are a subset of the elements in 26 U.”
United States v. Ronald N. Fern, 696 F.2d 1269 (11th Cir. 1983). · cites it 4× “Fern first urges that he could not be prosecuted under § 1001 because the application of the statute in this case would reach a patently absurd result.”
United States v. Yurek (Wendy), 925 F.3d 423 (10th Cir. 2019). · cites it 2× “§ 7206 (1), (3), (4), and (5) ), • willfully filing a fraudulent return, statement, or other document ( 26 U.S.C. § 7207 ), *441 • making false statements to purchasers or lessees relating to a tax ( 26 U.”
United States v. The Southland Corp. & S. Richmond Dole & Eugene Mastropieri, the Southland Corp., Eugene Mastropieri, 760 F.2d 1366 (2d Cir. 1985). · cites it 2× “Refusal to Charge a Violation of 26 U.S.C. § 7207 as a Lesser Included Offense Section 7207 of the IRC provides: Any person who willfully delivers or discloses to the Secretary any list, return, account, statement, or other document, known by him to be fraudulent or to be false…”
United States v. Lloyd E. Humphreys, 982 F.2d 254 (8th Cir. 1993). · cites it 2× “§ 7201 ), and replaced the count with the lesser included offense of misdemeanor filing of a false return ( 26 U.S.C. § 7207 ). II. A. Suppression of Evidence Humphreys’s motion to suppress evidence stems from a search of his law office, conducted pursuant to two search warrants…”
United States v. Roy Bradley, Sr., 917 F.3d 493 (6th Cir. 2019). “1985) (holding that conspiracy to submit fraudulent tax documents in violation of 26 U.S.C. § 7207 is not a lesser-included offense of conspiracy to defraud the United States); United States v.”
United States v. Solomon Gaines, 690 F.2d 849 (11th Cir. 1982). · cites it 2× “First, he contends that the district court should have instructed the jury that the misdemeanor provisions of 26 U.S.C. § 7207 11 were lesser included offenses under the charged crime.”
In Re Disciplinary Action Against Dvorak, 554 N.W.2d 399 (Minn. 1996). · cites it 3× “On March 15, 1995, Dvorak and law' partner John Moosbrugger each pleaded guilty in federal district court to a misdemeanor count of willfully filing a fraudulent or false tax return in violation of 26 U.S.C. § 7207 (1994). Although all four partners in the Moosbrug-ger firm…”
United States v. Donald F. Bettenhausen & Bernice A. Bettenhausen, 499 F.2d 1223 (10th Cir. 1974). · cites it 3× “They say instead that 26 U.S.C.A. § 7207 , a misdemeanor statute specifically dealing with delivering any document, etc.”
United States v. Tomeny, 144 F.3d 749 (11th Cir. 1998). · cites it 2× “1983) ( 26 U.S.C. § 7207 ); Anderez, 661 F.2d at 407 ( 31 U.”
United States v. Andrew Tsanas, 572 F.2d 340 (2d Cir. 1978). “He contends that the court should also have charged a violation of the first sentence of 26 U.S.C. § 7207 . 8 Just as § 7201 is the “capstone” of tax offenses, § 7207 lies at the bottom.”
United States v. Bailey, 789 F. Supp. 788 (N.D. Tex. 1992). · cites it 4× “Violations of 26 U.S.C. § 7207 On numerous occasions, Clem Bailey presented false documents to the Internal Revenue Service on behalf of his clients.”
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