U.S. Court of Appeals Affirms Denial of Coram Nobis Relief in Tax Evasion Case

The U.S. Court of Appeals for the Second Circuit affirmed the district court’s denial of a petition for writ of error coram nobis seeking to vacate tax evasion convictions and a $4.2 million restitution order. The petitioner, a disbarred attorney convicted in 2018 of conspiracy to evade federal taxes and failure to file personal returns, argued that an alleged agreement between the IRS and foreign tax authorities relieved him of filing obligations for certain years and that the restitution order created impermissible double taxation. The court held that coram nobis relief requires extraordinary circumstances, which were not present. The purported ...