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Charges of Conspiracy: A Potential Consequence of the Supreme Court’s Recent Decision in Marinello

In Conspiracy, Obstruction of Justice by Zach MontgomeryLeave a Comment

On March 21, 2018, the Supreme Court issued its decision in Marinello v. United States.[1]The holding of the Court focused on restricting the scope of the Omnibus Clause of section 7212(a) of the Internal Revenue Code. In particular, the Court held that the Government must prove that a defendant was aware of a pending tax-related proceeding (or could reasonably foresee …