USA v. Crandell, No. 22-60350 (5th Cir. 2023)
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Defendant is a medical doctor. He contracted with two hospitals, one in Mississippi and one in Alabama. He usually made $30,000 to $40,000 per month. Because he was a contractor, the hospitals did not withhold any wages for tax purposes— Defendant was solely responsible for satisfying his federal tax obligations. From 2006 through 2012, Defendant did not pay any income taxes or file any timely tax returns. A jury found him guilty of tax evasion in violation of 26 U.S.C. Section 7201. Defendant raised two claims on appeal: first, that the evidence at trial was insufficient to support a conviction for tax evasion under Section 7201; and second, that the district court abused its discretion by denying his motion for a mistrial.
The Fifth Circuit affirmed. The court explained that even if it was legitimate for Defendant to deduct IRS garnishments from his income, that does not explain why Defendant neglected to mention key assets on the form—such as the $50,000 gun collection and the corporate bank accounts that he used to pay personal expenses. Moreover, the prosecution presented evidence suggesting that he manipulated his wages to artificially depress his income at the time he submitted Form 433-A.
Further, even assuming that the district court was right to sustain the defense’s objection, Defendant offered no reason to believe that the questions incurably prejudiced the jury. Given the weight of evidence presented to the jury in this case, there is no “significant possibility” that these two questions had a substantial impact on the verdict.
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