In a series of recent decisions, the U.S. Supreme Court has reined in prosecutors’ use of broadly worded statutes and clauses to charge criminal conduct. The federal tax code could be the justices’ next target.
Jenner & Block’s Matthew Hellman will face the government this term in Marinello v. United States in which, he argues, prosecutors are using an “omnibus” clause in the tax code as an “uber tax-crime statute” that puts at risk unwary businesses and individuals.
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