Achilli v. United States

Background

A man was charged in a three-count indictment for willfully attempting to evade federal income taxes by filing a false return and was convicted and sentenced to concurrent prison terms and fines. An appeals court reversed one count but affirmed two others, and the Supreme Court agreed to decide a focused legal question about which criminal law applies to this conduct.

Reasoning

The central question was whether a long-standing, general misdemeanor law that forbade delivering a false return applied to income tax evasion, or whether the income-tax-specific felony law should govern. The Court reviewed the history of successive revenue laws from 1798 through the early 20th century and concluded that more specific income-tax statutes and later enactments effectively limited the reach of the old general provision. Finding that the specialized income-tax felony provision properly covered attempts to evade income tax by filing false returns, the Court held the general misdemeanor statute did not apply and affirmed the convictions.

Real world impact

The decision lets prosecutors rely on the income-tax-specific felony statute when pursuing willful attempts to evade income tax by false returns, rather than the older general misdemeanor return law. The ruling resolves a disputed overlap between statutes and preserves tougher felony penalties for such evasion. The Court’s ruling is final for this case, though one Justice warned the decision could unsettle many past prosecutions under the older statute.

Dissents or concurrances

A dissent argued the general misdemeanor provision had long been treated as applicable to income tax returns and warned the majority’s view could affect scores of past convictions and pending cases, citing specific case statistics.