United States v. Upton

The relationship between the concealment at issue in Upton’s conspiracy to commit money laundering and the concealment associated with his subsequent tax crimes is complex. The majority misapplies the relevant legal principles and, consequently, wrongly concludes that Upton’s failure to file a 1999 tax return was conduct within the scope of the money laun*17dering conspiracy. In so doing, the majority embraces the government’s misguided attempt to remedy a statute of limitations problem by stretching the money laundering conspiracy beyond its justifiable limits to include Upton’s independent tax…