'Daugerdas v. Commissioner': The Seventh Circuit Addresses Tax Restitution

May 19, 2026  |  New York Law Journal

Under section 6201(a)(4)(A) of the Internal Revenue Code, the Internal Revenue Service has the authority to collect restitution ordered in criminal tax cases using the tools available to collect taxes, penalties, and interest. In Daugerdas v. Commissioner of Internal Revenue, decided in March 2026, the Seventh Circuit confirmed that the IRS may assess and collect criminal tax restitution under Section 6201(a)(4)(A), even when the underlying conviction is a Title 18 offense. In his latest New York Law Journal article, Jeremy Temkin analyzes the court’s decision, including its conclusion that the IRS may use its full administrative collection powers and is not bound by a payment schedule set by the sentencing court.

'Daugerdas v. Commissioner': The Seventh Circuit Addresses Tax Restitution