In Marinello v United States, 584 U. S. ____ (2018), the U.S. Supreme Court held that prosecutors must establish a “nexus” between a particular administrative proceeding and a taxpayer’s conduct in order to obtain a conviction under the “Omnibus Clause” in Section 7212(a) of the Internal Revenue Code. The statute forbids “corruptly or by force or threats of force . . . obstruct[ing] or imped[ing], or endeavor[ing] to obstruct or impede, the due administration of [the Internal Revenue Code].”
