Willfulness

Attempt to evade or defeat (usually involves concealment or deception) tax or payment thereof

Tax deficiency

Willfulness

Requirement to collect, truthfully account for, and pay over employment taxes

Either failure to collect any tax or failure to truthfully account for and pay over any tax or both

Willfulness

Requirement to file a return, pay an estimated tax or tax, maintain records, or supply information

Failure to file a return, pay an estimated tax or tax, maintain records, or supply information

Willfulness

Subject to reporting requirement relating to cash of more than $10,000 received in trade or business

Evasion of reporting requirement by:

Duty to deduct and withhold employment tax or income tax (26 USC 3102(a), 3402(a)

Duty to timely furnish to the employee a written statement showing specified information concerning the deductions (26 USC 6051)

Furnishing a false or fraudulent statement to an employee, or the failure to furnish a statement to an employee at the required time and in the required manner

Willfulness

Duty to supply information to employer regarding income tax withholding (26 USC 3402(f)(2))

Furnishing false or fraudulent information or failure to supply information, which would require an increase in tax to be withheld

Willfulness

Making and subscribing a return or other document under penalties of perjury

The return, statement or other document, which was false as to a material matter

Belief that it is not true and correct as to every material matter

Willfulness

Aiding or assisting in, procuring, counseling, or advising the preparation or presentation of a document in connection with matters arising under the internal revenue laws

Document was false as to a material matter

Willfulness

Tax imposed on property

Property on which tax is imposed or will be imposed or levy is authorized

Removal or concealment

Intent to evade or defeat assessment or collection of tax

Willful concealment of property or

Willful withholding, falsifying and destroying records

Receives, withholds, destroys, mutilates, or falsifies any book, document, or record, or makes any false statement.

Wilfulness

Delivery or disclosure to any officer or employee of the Internal Revenue Service of any list, return, account, statement, or other document Return, statement, or other document is false or fraudulent as to a material matte

Knowledge of material falsity

Corrupt effort, endeavor, or attempt

To impede, obstruct or interfere with

Due administration of Title 26

Use of force or threat

To intimidate, impede or obstruct

An officer or employee of the U.S. acting in official capacity under Title 26

Forcible rescue or attempt to forcibly rescue

Seized property

Knowledge of seizure

Taxpayer was a person required to collect, account for, and pay over income tax withholding on wages and FICA taxes

Taxpayer was notified of the failure to collect, account for, and pay over

Taxpayer failed to collect, account for, and pay over the taxes, while not entertaining a reasonable doubt as to whether the law required the taxpayer to do so, and the failure was not due to circumstances beyond the taxpayer’s control

Fails to register in connection with taxable purchase -diesel fuel and special motor fuels, or

Falsely represents that he is registered, or

Willfully makes false statement in an application for registration.

Bankruptcy proceeding was in existence;

Individual fraudulently concealed the property from the custodian; and

Property belonged to the bankruptcy estate.

Existence of a bankruptcy proceeding;

Statement under oath;

Statement must be false; and

Statement was made knowingly and fraudulently makes a false oath or account in or in relation to any case under title 11.

Existence of a bankruptcy proceeding;

Individual made a false declaration, certificate, verification, or other statement in relation to the bankruptcy proceeding;

Statement was knowingly and fraudulently makes a false declaration, certificate, verification, or statement under penalty of perjury as permitted under Section 1746 of Title 28, in or in relation to any case under title 11.

Bankruptcy proceedings have commenced; Individual presented or caused to be presented a proof of claim in the bankruptcy;

Proof of claim was false as to a material matter; and

Individual knew the proof of claim was false and acted knowingly and fraudulently presents any false claim for proof against the estate of a debtor, or uses any such claim in any case under title 11, in a personal capacity or as or through an agent, proxy, or attorney;

Individual receives a material amount of property from a debtor

Such transfer occurred after the filing of a case under Title 11; and

Acts were done with the intent to defeat the provisions of Title 11.

Individual gives, offers, receives, or attempts to obtain money or property, remuneration, compensation, reward, advantage, or promise for acting or forbearing to act in any case under Title 11; and

Action was made knowingly and fraudulently.

Individual fraudulently transferred or concealed the defendant's property or the property of another; an

Such act of transfer or concealment was done with the intent to defeat the provisions of Title 11, or in contemplation of a case under Title 11.

Bankruptcy proceeding existed

Individual concealed, destroyed, or mutilated the documents;

Such documents related to the property or financial affairs of the debtor; and

Individual acted knowingly and fraudulently.

Bankruptcy proceeding existed;

Individual withheld from the trustee entitled to its possession; books, documents, records, or papers;

Such documents related to the property or financial affairs of the debtor; an

Individual withheld the documents knowingly and fraudulently.

Defendant devised or intended to devise a scheme or artifice to defraud; and

For the purpose of executing or concealing such scheme or artifice or attempting to do so;

Files a petition under Title 11; or

Files a document in a proceeding under Title 11; or

Makes a false or fraudulent representation, claim, or promise concerning or in relation to a proceeding under Title 11

An agreement, combination, or conspiracy to defraud the United States

By obtaining or aiding to obtain the payment of any false, fictitious or fraudulent claim.

Knowingly makes or presents (statute does not require that person providing false information to return discounter* who filed return actually file return to be guilty under 287)

False, fictitious or fraudulent claim

Knowing that claim filed is false, fictitious or fraudulent.

The general conspiracy statute encompasses two distinct types of conspiracies;

Essential elements of a Section 371 offense are:

Either:

Knowingly and willfully

In a matter within the jurisdiction of a department or agency of the United States

False matter was of a material nature.

Whoever, knowing that property involved in a financial transaction represents proceeds of a specified unlawful activity (SUA).

Conducts such a financial transaction, which in fact involves proceeds of a SUA: