INSIGHT: Second Circuit Affirms $10 Million Fine in Tax Evasion Case

August 13, 2018

In a per curiam decision issued on July 27, 2018, the Second Circuit affirmed a $10 million fine imposed on Morris Zukerman as part of a sentence for tax evasion in United States v. Zukerman, No. 17-948 (Katzmann, Kearse, Pooler). The court summarized its reason for affirming the fine, which was well above the $250,000 Guidelines ceiling, by writing that ‘‘Zukerman, a very wealthy man who has repeatedly and brazenly committed sophisticated tax fraud—a rarely caught and more rarely punished offense that undercuts the functioning of state and federal governments—ought to pay a fine
hefty enough to take any financial benefit out of his crimes and to give pause to others who might be tempted to commit similar crimes.’’

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