United States v. Rampton, No. 13-4116 (10th Cir. 2014)Annotate this Case
Defendant April Rampton received a large tax-refund check from the IRS after she submitted false tax forms. She claimed that the refund check was a government pronouncement that her actions were legal. After receiving her refund she helped others submit false tax returns using the same method. Defendant was convicted on nine counts of aiding and abetting the filing of false and fraudulent claims for income-tax refunds. On appeal, she argued that the district court's refusal to instruct the jury on the defense of entrapment by estoppel deprived her of a fair trial. The Tenth Circuit concluded defendant was not entitled to an entrapment-by-estoppel instruction because it would have been unreasonable to infer the legality of her conduct from the payment of the refund.