The following excerpt is from United States v. Little, No. 18-3622-cr, No. 19-445-cr (2nd Cir. 2020):
Little next argues that the counts of failure to file were improperly joined in the indictment. "Tax counts can properly be joined with non-tax counts where it is shown that the tax offenses arose directly from the other offenses charged. The most direct link possible between non-tax crimes and tax fraud is that funds derived from non-tax violations either are or produce the unreported income." United States v. Turoff, 853 F.2d 1037, 1043 (2d Cir. 1988) (cleaned up). Little's contention is that the failure-to-file counts had nothing directly to do with the broader Seggerman conspiracy.
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