The Third Circuit Court of Appeals has upheld the conviction of Brandon L. Aumiller for tax evasion, affirming the lower court's decisions regarding the indictment and evidence presented at trial. This ruling, filed on July 1, 2026, affects Aumiller, who was found guilty of attempting to evade tax payments owed to the Internal Revenue Service (IRS). The case highlights the importance of accurate financial disclosures to tax authorities.
Aumiller faced two counts of tax evasion under 26 U.S.C. § 7201, stemming from his actions between 2011 and 2017. The IRS had been attempting to collect unpaid taxes from him and his business. In December 2022, Aumiller was indicted for allegedly using undisclosed bank accounts to evade tax collection. The government claimed that he submitted false financial disclosure forms to the IRS, failing to report these accounts. Aumiller argued that the government did not prove he engaged in any affirmative act of evasion within the statute of limitations, which is six years for tax evasion cases.
The case reached the Third Circuit after Aumiller's motions to dismiss the indictments and for a judgment of acquittal were denied by the District Court. His defense claimed that the government did not provide sufficient evidence of any act of evasion occurring after December 8, 2016, the date of the original indictment. The District Court ruled against him, leading to his appeal.
The Third Circuit, led by Circuit Judge Shwartz, affirmed the lower court's ruling. The court found that Aumiller's actions, specifically the submission of false financial disclosure forms, constituted an affirmative act of evasion within the statute of limitations. The court stated, "The filing of a Form that intentionally omitted assets from it constitutes an affirmative act of evasion." The judges emphasized that the indictment sufficiently charged Aumiller with engaging in acts of evasion by failing to disclose his bank accounts.
During the trial, the government presented evidence showing that the IRS had informed Aumiller about the collections process and that he had been required to disclose all bank accounts. Witnesses testified that Aumiller had personal and business accounts that were not reported on the forms he submitted. The jury found him guilty on both counts of tax evasion.
The ruling has significant implications for tax law and enforcement. It reinforces the notion that failing to disclose financial information can lead to serious legal consequences, including criminal charges. The court's opinion clarifies that any act intended to mislead the IRS can be considered an affirmative act of evasion, which is crucial for future tax evasion cases.
The court's decision may set a precedent for how similar cases are handled in the future. It emphasizes the responsibility of taxpayers to provide accurate and complete information to tax authorities. This ruling could affect other individuals facing similar charges, as it highlights the importance of thorough financial disclosure.
Looking ahead, Aumiller has the option to appeal the ruling to the Supreme Court, although it is unclear if he will pursue that route. There are no related cases pending at this time. The Third Circuit's opinion serves as a reminder of the serious nature of tax evasion and the legal obligations of taxpayers to report their financial information accurately.