The case of Rogersville, Tennessee defendant Brian Leo Snow unfolded over the course of three Department of Justice (DOJ) press releases, respectively issued May 2018, July 2018, and November 2018. In May, an indictment against Snow was unsealed, revealing that multiple charges had been filed by federal prosecutors, including allegations of “filing false claims for tax refunds,” in addition to obstructing internal revenue laws. Less than two months later, he pleaded guilty in Tennessee federal court, admitting to a fraud scheme that spanned nearly a decade. By November, Snow had been sentenced to a two-and-a-half-year prison term, to be followed by supervised release – and accompanied, like most tax-related prison sentences, by hefty civil fines.
On May 16, 2018, Principal Deputy Assistant Attorney General Richard E. Zuckerman, who is part of the DOJ’s Tax Division, issued a statement confirming that Snow had been charged with filing false tax returns, which was done repeatedly over a nine-year period, thereby obstructing internal revenue laws. Respectively, these crimes constitute violations of (1) 26 U.S. Code § 7206 (pertaining to fraud and false statements), specifically 26 U.S. Code § 7206(1) (pertaining to willfully making and subscribing a false return), and (2) 26 U.S. Code § 7212 (pertaining to attempts to interfere with administration of internal revenue laws, otherwise referred to as “tax obstruction”).
In addition to the tax charges, which are similar to those we often cover on our tax law blog, Snow was also accused of “filing fraudulent multi-million dollar liens against government employees” – namely “an IRS revenue officer [i.e. an IRS debt collector], an Assistant United States Attorney, and a United States District Court Judge.”
Furthermore, Snow “filed a document with the Hawkins County Register of Deeds [where Rogersville is located] in an attempt to terminate tax liens filed against him by the IRS.” (As our tax lien attorneys discussed in a previous article, the financial effects of IRS tax liens – which are sometimes filed against taxpayers who fail to pay tax debts – tend to include damaged credit scores and, in turn, increased difficulty in obtaining loans.)
The scope of these offenses, to which Snow later admitted, was vast – both in terms of the time and money involved. In addition to failing to pay taxes for nearly a decade, Snow claimed he was owed refunds in the approximate amount of $144 million (when, for most taxpayers, the average refund is closer to several thousand dollars). In reality, it was in fact Snow who owed the IRS: approximately $150,000. This outstanding IRS tax debt resulted in the collection efforts which, ultimately, spurred Snow to file “false retaliatory liens” targeting government officials who were “involved in the attempts to collect Snow’s back taxes.”
The July press release noted that, upon sentencing, Snow would face up to 15 years in prison. The press release issued in November revealed that Snow had been sentenced to 30 months: a “light” sentence, perhaps, in comparison to the maximum, yet still more than two years in federal prison. Moreover, Snow will be subject to a three-year period of supervised release – during which he will be subject to certain rules and surveillance requirements, not unlike probation – after he is released.
In addition to being sentenced to prison time and supervised release, Snow was also ordered to pay IRS restitution just over $154,000 – a far cry from the multi-million-dollar tax refund he attempted to claim.
The IRS has years to audit your tax returns – and in some cases, an unlimited amount of time to investigate your records. If you failed to pay taxes, obstructed or retaliated against IRS debt collectors, claimed a tax refund that you were not entitled to receive, or engaged in other types of tax fraud, you need the protection and assistance of an experienced criminal tax attorney. With deft and skillful legal representation, it may be possible to mitigate the civil and/or criminal penalties you are facing.
If you need help fighting a tax evasion charge or related criminal charges involving tax fraud, contact the Tax Law Office of David W. Klasing online right away to set up a reduced-rate consultation. You can also contact us by calling (800) 681-1295. With tax offices strategically located throughout Northern and Southern California, we are available to serve clients statewide.
Also, we’ve expanded our offices! In addition to our offices in Irvine and Los Angeles, the Tax Law Offices of David W. Klasing now have offices San Bernardino, Santa Barbara, Panorama City, Oxnard, San Diego, Bakersfield, San Jose, San Francisco, Oakland and Sacramento.
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