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Jeremy H. Temkin

On March 21, the Supreme Court handed down its decision in Marinello v. United States, 584 U.S. __ (March 21, 2018), which restricted 26 U.S.C. §7212(a)’s omnibus clause to cases where the government can prove “a ‘nexus’ between the defendant’s conduct and a particular administrative proceeding, such as an investigation, an audit, or other targeted administrative action.” Given that the Department of Justice had long used that provision to prosecute conduct predating audits and investigations, Marinello represents a significant limitation on the government’s use of the statute. See Jeremy H. Temkin & Miriam Glaser, “Marinello v. United States: SCOTUS Reins in the Tax Division,” 3 For the Defense 2, 28 (May 2018).

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