CCA 202141015
Assessment of Criminal Restitution
ID:
UILC:
CCA_2020080314432844
6201.01-06
Number: 202141015
Release Date: 10/15/2021
From: ---
Sent: Monday, August 3, 2020 2:43:28 PM
To: ---
Cc: ---
Bcc:
Subject: RE: Westbrooks applicability---
I agree with the conclusion that the smaller amount, which is attributed to the 7206(1) counts, is subject to Westbrooks, and the larger amount, which is attributed to the 18 USC 287 counts, is not. The conduct alleged and proven to support each of those amounts does not overlap, so the one does not include the other. The court treated them separately in the judgment, covering the Title 26 counts as a condition of supervised release and the Title 18 counts as ordered separately, and so too should we.
Please call if you have any further questions about this matter.
Source: view the official PDF
Nearby sections (25 sections)
- plr-202141004 · Special Rules for Capital Gains Invested in Opportunity…
- plr-202141003 · Reg. 301.7701-3 Classification of Certain Business…
- plr-202141002 · Inadvertent Terminations
- plr-202141001 · Modified Accelerated Cost Recovery System
- cca-202141023 · Authority to Make Credits or Refunds
- cca-202141022 · Qualified Conservation Contribution
- cca-202141021 · Interest on Underpayment, Nonpayment, or Extensions of…
- cca-202141020 · Assessment of Criminal Restitution
- cca-202141019 · Assessment of Criminal Restitution
- cca-202141018 · Assessment of Criminal Restitution
- cca-202141017 · Assessment of Criminal Restitution
- cca-202141016 · Assessment of Criminal Restitution
- cca-202141015 · Assessment of Criminal Restitution
- cca-202141014 · Assessment of Criminal Restitution
- cca-202141013 · Assessment of Criminal Restitution
- cca-202141012 · Assessment of Criminal Restitution
- cca-202141011 · Assessment of Criminal Restitution
- cca-202141010 · Assessment of Criminal Restitution
- cca-202141009 · Assessment of Criminal Restitution
- cca-202141008 · Assessment of Criminal Restitution
- cca-202141007 · (Pre-TCJA) Affiliated Group Rules
- cca-202141006 · Innocent spouse (including Sections 66, 6013)
- plr-202140016 · Source Rules for Personal Property Sales
- plr-202140015 · Inadvertent Terminations
- plr-202140014 · Public Utility Property