Marinello v. United States

Decided March 21, 2018. Stephen Gerald Breyer delivered the opinion of the Court.

Docket 16-1144 · 584 U.S. 1 · Cited 82 times

To convict a defendant under 26 U. S. C. §7212(a)—which forbids “corruptly or by force or threats of force . . . obstruct[ing] or imped[ing], or endeavor[ing] to obstruct or impede, the due administration of [the Internal Revenue Code]”—the Government must prove the defendant was aware of a pending tax-related proceeding, such as a particular investigation or audit, or could reasonably foresee that such a proceeding would commence.

The Court’s statement of the holding, from the opinion’s syllabus. The syllabus is prepared by the Reporter of Decisions and is not part of the opinion of the Court — read the official opinion for authority.

Read the official opinion (PDF, supremecourt.gov) (opens primary source in a new tab)

Stephen Gerald Breyer’s profile · All opinions since October Term 2017 · The Supreme Court

Source: Supreme Court of the United States, slip opinions (2018). Citation count from the Free Law Project’s CourtListener bulk data. Data last verified 2026-07-02. Informational only; verify against the primary source before relying. Not a consumer report (FCRA).