Two Underdogs Prevail in As Many Days

As a lifelong Philadelphia Eagles fan, it pains me to acknowledge the New York Giants as the Super Bowl Champions. Okay, enough said and on to underdog number two, Mr. Snipes. Unreal.

Despite, or because of (if you are a regular reader of this blog) a 600 page diatribe in which Mr. Snipes attacked any and everyone who has anything to do with administration of the Internal Revenue Laws, Mr. Wesley Snipes was acquitted of the felony charges for which he faced a potential of 16 years in prison. Instead, Mr. Snipes will face sentencing for misdemeanor failure to file tax returns offenses wherein he faces 3 years in jail. In the normal course, there would be little to no jail time for a failure to file offense. The exceptions are where there is a pattern of failure to file or, as here, there is some other relevant conduct on the part of a taxpayer for the court to take into consideration in the context of determining the appropriate sentence.  Relevant conduct is that activity of a person that even though it may be uncharged criminally it is significant enough to warrant consideration for the prupose of imposing a criminal sentence. I would say Mr. Snipes' defense team did a terrific job in mitigating the intent component of the offenses Mr. Snipes was charged with having committed. Now, let's see if we can keep him out of jail. Then he and Eli can go to Disney.

 John M. Hanamirian