Venue for Tax Crimes

September 15, 2026  |  New York Law Journal

In Abouammo v. United States, the Supreme Court reinforced that venue in criminal prosecutions generally depends on where the conduct constituting the offense occurred. In his latest New York Law Journal article, Jeremy Temkin considers what this decision means for criminal tax prosecutions, where offenses often span multiple jurisdictions. Examining Abouammo and decisions in two criminal tax cases, United States v. Chollet and United States v. O’Donoghue, he explains why Abouammo is unlikely to significantly alter the analysis of venue in most tax offenses, while highlighting opportunities for defendants to challenge the government’s chosen venue.

Venue for Tax Crimes