A man's first duty, a young man's at any rate, is to be ambitious.
- G. H. Hardy (1877-1947)Fourth Circuit Affirms Criminal Tax Sentences in Unpublished Opinion that Is Good for Teaching (5/162/24)
In United States v. Rice, 2024 U.S. App. LEXIS 11329, 2024 WL 2078454 (4th Cir. 5/9/24), CA4 here and GS here, an unpublished opinion, the Court affirmed the Rices’ convictions and sentencing. Normally, I don’t write on unpublished opinions, but I thought this opinion had some interesting facets which are good teaching opportunities for students or relatively new tax crimes practitioners.
First, the opinion says at the opening (slip op. 3):
James and Susan Rice (collectively, Appellants) appeal their conviction and sentence on ten counts relating to their failure to file tax returns and failure to pay employment taxes to the Internal Revenue Service (IRS). Finding no error, we affirm.
Second, the Court provides a short summary of the facts, among which was the following (slip op. 4):
Appellants were jointly represented by trial counsel.