18 U.S.C. § 550
Section 550 · False claim for refund of duties
Amended 2 times on record
Applied in 143 court decisions — leading case Pinkerton v. United States (1946)
Most recently applied in United States v. Figueroa-Cartagena (July 2010)
Cases citing this section usually also cite 18 U.S.C. § 2 · 19 U.S.C. § 1593 · 18 U.S.C. § 371
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Whoever knowingly and willfully files any false or fraudulent entry or claim for the payment of drawback, allowance, or refund of duties upon the exportation of merchandise, or knowingly or willfully makes or files any false affidavit, abstract, record, certificate, or other document, with a view to securing the payment to himself or others of any drawback, allowance, or refund of duties, on the exportation of merchandise, greater than that legally due thereon, shall be fined under this title or imprisoned not more than two years, or both, and such merchandise or the value thereof shall be forfeited.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on section 1590 of title 19, U.S.C., 1940 ed., Customs Duties (June 17, 1930, ch. 497, title IV, §590, 46 Stat. 750).
Reference to felony, contained in words “such person shall be guilty of a felony” was omitted as unnecessary in view of definition of felony in section 1 of this title. This, too, was the policy adopted by the codifiers of the 1909 Criminal Code. (See S. Rept. 10, pt. I, pp. 12, 13, and 14, 60th Cong., 1st sess.)
Words “and upon conviction thereof” before “shall be punished” were also omitted as unnecessary, since punishment cannot be imposed until a conviction is secured.
Changes were made in phraseology.
Amendments
1994—Pub. L. 103–322 substituted “fined under this title” for “fined not more than $5,000”.