SANDRA BROWN Quoted in Tax Notes
An amendment to the U.S. Sentencing Guidelines Manual that takes effect November 1 will include a new two-level reduction for true first offenders having their first contact with the criminal justice system. The amendment, subject to certain exceptions, will apply to offenders with no criminal history points, including offenders with no prior convictions. In adopting this definition of “zero-point offenders,” the Commission opted to hew to the long-standing and carefully crafted criminal history rules set forth in Chapter Four, regarding which prior convictions count for criminal history purposes and which do not. Notably, this reduction is likely to be in play for those charged with certain white collar crimes, including criminal tax violations.
Sandra R. Brown is a Principal at Hochman Salkin Toscher Perez P.C., and former Acting United States Attorney, First Assistant United States Attorney, and the Chief of the Tax Division of the Office of the U.S. Attorney (C.D. Cal). Ms. Brown specializes in representing individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.