26 U.S.C. § 7201
Section 7201 · Attempt to evade or defeat tax
Amended 2 times on record
Applied in 2,427 court decisions — leading case MacKey v. United States (1971)
Most recently applied in United States v. Ray (June 2025)
Applied most in the Ninth Circuit Circuit (195 decisions)
Cases citing this section usually also cite 26 U.S.C. § 7206 · 18 U.S.C. § 371 · 26 U.S.C. § 7203
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.
Any person who willfully attempts in any manner to evade or defeat any tax imposed by this title or the payment thereof shall, in addition to other penalties provided by law, be guilty of a felony and, upon conviction thereof, shall be fined not more than $100,000 ($500,000 in the case of a corporation), or imprisoned not more than 5 years, or both, together with the costs of prosecution.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1982—Pub. L. 97–248 substituted “$100,000 ($500,000 in the case of a corporation)” for “$10,000”.
Effective Date of 1982 Amendment
Section 329(e) of Pub. L. 97–248 provided that: “The amendments made by this section [amending this section and sections 7203, 7206, and 7207 of this title] shall apply to offenses committed after the date of the enactment of this Act [Sept. 3, 1982].”
Cross References
Costs in criminal proceedings, see section 1918 of Title 28, Judiciary and Judicial Procedure.
Definition of person, see section 7343 of this title.
Effective date of this chapter, see section 7851 of this title.
Penalty for—
Delivery or disclosure of false or fraudulent return, statement or other document, see section 7207 of this title.
Making or subscribing false return, see section 7206(1) of this title.
Period of limitation—
Criminal prosecutions arising under internal revenue laws, see section 6531 of this title.
Offenses not capital, see section 3282 of Title 18, Crimes and Criminal Procedure.