26 U.S.C. § 7212

Attempts to interfere with administration of internal revenue laws

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(a) Corrupt or forcible interference

Whoever corruptly or by force or threats of force (including any threatening letter or communication) endeavors to intimidate or impede any officer or employee of the United States acting in an official capacity under this title, or in any other way corruptly or by force or threats of force (including any threatening letter or communication) obstructs or impedes, or endeavors to obstruct or impede, the due administration of this title, shall, upon conviction thereof, be fined not more than $5,000, or imprisoned not more than 3 years, or both, except that if the offense is committed only by threats of force, the person convicted thereof shall be fined not more than $3,000, or imprisoned not more than 1 year, or both. The term “threats of force”, as used in this subsection, means threats of bodily harm to the officer or employee of the United States or to a member of his family.

(b) Forcible rescue of seized property

Any person who forcibly rescues or causes to be rescued any property after it shall have been seized under this title, or shall attempt or endeavor so to do, shall, excepting in cases otherwise provided for, for every such offense, be fined not more than $500, or not more than double the value of the property so rescued, whichever is the greater, or be imprisoned not more than 2 years.

(Aug. 16, 1954, ch. 736, 68A Stat. 855.)
Notes of Decisions
Cited in 476 cases (58 in the last 5 years), 1968–2026 · leading case: United States v. Coplan, 703 F.3d 46 (2d Cir. 2012).
United States v. Coplan, 703 F.3d 46 (2d Cir. 2012). · cites it 15× “” 26 U.S.C. § 7212 (a). 9 Counts Six and Seven charged Vaughn and Coplan, respectively, with making false statements to the IRS, in violation of 18 U.”
United States v. Ronald Francis Croteau, 819 F.3d 1293 (11th Cir. 2016). · cites it 6× “§ 287 and 2, and one count of corruptly interfering with the administration of internal revenue laws, in violation of 26 U.S.C. § 7212 (a). Croteau appeals both (1) the sufficiency of the evidence supporting the jury’s verdict, and (2) the procedural and substantive…”
Marinello v. United States, 138 S. Ct. 1101 (2018). · cites it 6× “In 2012, the Government indicted Marinello for violating, among other criminal tax statutes, a provision in 26 U. S. C. §7212 (a) known as the Omni- bus Clause, which forbids “corruptly or by force or threats of force .”
United States v. Marinello, 839 F.3d 209 (2d Cir. 2016). · cites it 11× “Under one of the counts of conviction, Marinello was charged with violating 26 U.S.C. § 7212 (a). One portion of the statute imposes criminal liability on one who “corruptly or by force or threats of force .”
United States v. Pansier, 576 F.3d 726 (7th Cir. 2009). · cites it 5× “The language of Count One of the indictment reveals that the count was not duplicitous and charged Pansier only with obstructing the due administration of the IRS under the omnibus clause of 26 U.S.C. § 7212 (a). We further conclude that it is not an element of 26 U.”
United States v. David N. Bowman, 173 F.3d 595 (6th Cir. 1999). · cites it 13× “Bowman appeals his August 2, 1996 conviction of one count of corruptly endeavoring to obstruct or impede the due administration of the Internal Revenue laws in violation of 26 U.S.C. § 7212 (a), one count of filing false documents with the Internal Revenue Service in violation…”
United States v. James Thomas McBride, 362 F.3d 360 (6th Cir. 2004). · cites it 4× “§ 1503 , obstructing the due administration of the internal revenue laws in violation of 26 U.S.C. § 7212 (a), and three counts of bankruptcy fraud in violation of 18 U.”
United States v. Ward Franklin Dean, 487 F.3d 840 (11th Cir. 2007). · cites it 5× “§ 7201 , and attempted interference with the administration of internal revenue laws, 26 U.S.C. § 7212 (a). Dean challenges his conviction on a number of grounds, arguing that there was insufficient evidence to convict him of the attempt at obstruction and that the jury received…”
United States v. Tamny Westbrooks, 858 F.3d 317 (5th Cir. 2017). · cites it 4× “Westbrooks was convicted under the omnibus clause of the statute, which makes it a crime to “in any ... way corruptly or by force or threats of force .”
United States v. Parse, 789 F.3d 83 (2d Cir. 2015). · cites it 6× “§§ 1341 and 2, and attempting to 18 interfere with the administration of the federal tax laws, in violation of 26 U.S.C. § 7212 (a), and found 19 some of his codefendants guilty of those and other tax-related offenses.”
United States v. Sorensen, 801 F.3d 1217 (10th Cir. 2015). · cites it 5× “' In 2013, after a series of proffers, the government charged him with violating 26 U.S.C. § 7212 (a) for corruptly endeavoring to obstruct and impede the due administration of the internal-revenue laws.”
United States v. Mubayyid, 658 F.3d 35 (1st Cir. 2011). · cites it 4× “§ 7206 (1), and one count (Count 8) of corruptly endeavoring to obstruct the administration of the Internal Revenue laws, in violation of 26 U.S.C. § 7212 (a). All four counts rest on Mubayyid’s answers to Question 76 on Care’s Form 990 for the tax years 1997, 1999, and 2000.”
— 26 U.S.C. § 7212(a) — 6 cases
United States v. Reno Varani, 435 F.2d 758 (6th Cir. 1970).
United States v. Mubayyid, 567 F. Supp. 2d 223 (D. Mass. 2008).
United States v. Shore, 143 F. Supp. 2d 74 (D. Mass. 2001).
United States v. Sidney Benjamin Miles, 440 F.2d 1175 (5th Cir. 1971).
United States v. Gutierrez (10th Cir. 2019).
— 26 U.S.C. § 7212(b) — 2 cases
United States v. Rodney R. Oliver, 421 F.2d 1034 (10th Cir. 1970).
United States v. Grady Lee Sanders, 862 F.2d 79 (4th Cir. 1988).
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