ABATax: Comments Concerning Proposed Amendments to the United States Sentencing Guidelines

Section of Taxation
Submission to the Federal Executive Branch

Comments Concerning Proposed Amendments to the United States Sentencing Guidelines

Introduction | Table of Contents | Download for printing

The following comments relating to the United States Sentencing Guidelines are the individual views of the members of the Section of Taxation who prepared them and do not represent the position of the American Bar Association or the Section of Taxation.

These Comments were prepared by individual members of the Committee on Civil and Criminal Tax Penalties. Principal responsibility was exercised by Bryan C. Skarlatos and Daniel T. Hartnett. The Comments were reviewed by John Barrie of the Section’s Committee on Government Submissions and by Karen Hawkins, Council Director for the Committee on Civil and Criminal Tax Penalties.

Although members of the Tax Section who participated in preparing and reviewing these comments represent clients who may be affected by the proposed amendments to the United States Sentencing Guidelines, no such member (or firm or organization to which such member belongs) has been engaged by a client to make a government submission with respect to, or otherwise to influence the development of, the specific subject matter of this proposal.

Contact:

Bryan C. Skarlatos
Kostelanetz & Fink, LLP
530 Fifth Avenue
New York, NY 10036
(212)808-8100
(212) 808-8108 (Fax)
bskarlatos@kflaw.com
Daniel T. Hartnett
Martin, Brown and Sullivan Ltd.
321 South Plymouth Court, 10th Floor
Chicago, IL 60604
(312) 360-5020
(312) 360-5026 (Fax)
hartnett@mbslaw.com

Date: March 27, 2001

Introduction

In the current amendment cycle, the Sentencing Commission is considering changes to United States Sentencing Guidelines, Part S (Money Laundering And Monetary Transaction Reporting) and Part T (Offenses Involving Taxation) (the "Proposed Amendments"). The Commission has invited comments on the Proposed Amendments. We appreciate the opportunity to offer the Commission the perspective of the defense practice with regard to criminal sentencing.