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Criminal Law: Aiding and Abetting-Tax Fraud-Appeal Waiver-Sentencing Challenges

Staff Report//May 7, 2026//

Criminal Law: Aiding and Abetting-Tax Fraud-Appeal Waiver-Sentencing Challenges

Staff Report//May 7, 2026//

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Defendant appealed the sentence and restitution order imposed following her guilty plea to aiding and assisting the preparation of a false tax return, pursuant to a plea agreement containing an appeal waiver.

Where the appeal waiver was valid and enforceable, the court affirmed defendant’s conviction and sentence where there was no competent evidence of government misconduct.

Judgment is affirmed; appeal is dismissed.

U.S. v. Smith (MLW No. 84715/Case No. 25-3293 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Eastern District of Arkansas, Marshall, J.


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