O111 Impeding Internal Revenue Service - Omnibus Clause

Official jury instruction text reproduced for information. It is not legal advice; the instruction given in a case depends on the facts and the court.

Instruction
O111
Statute
26 U.S.C. § 7212(a)
Edition
Eleventh Circuit Pattern Jury Instructions (Criminal Cases), revised July 2026
Official source
Official PDF, page 750

Elements

Quoted word for word from the official text. Eleventh Circuit Pattern Jury Instructions (Criminal Cases), revised July 2026.

(1) The Defendant can be found guilty of this crime only if all the following facts are proved beyond a reasonable doubt: the Defendant knowingly tried to obstruct or impede the due administration of the Internal Revenue laws in connection with a pending or impending Internal Revenue Service (IRS) proceeding or other targeted administrative action;

(2) the proceeding or action was pending or reasonably foreseeable by the Defendant at the time the Defendant engaged in the obstructive conduct; and

(3) the Defendant did so [corruptly] [by force] [and/or] [by threats of force].

Related practice page

Tax Fraud & Tax Evasion Defense in Miami

Official source: Official PDF, page 750

Official jury instruction text reproduced for information. It is not legal advice; the instruction given in a case depends on the facts and the court.

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