Coram Nobis, Procedural Default, and the Limits of Moore v. United States in Criminal Tax Jurisdiction: Commentary on United States v. Walcott (10th Cir. 2025)

Coram Nobis, Procedural Default, and the Limits of Moore v. United States in Criminal Tax Jurisdiction
Commentary on United States v. Walcott, No. 25‑1024 (10th Cir. Dec. 4, 2025)

I. Introduction

This commentary analyzes the Tenth Circuit’s unpublished order and judgment in United States v. Walcott, No. 25‑1024 (10th Cir. Dec. 4, 2025), where the court affirmed the denial of a petition for a writ of error coram nobis and a motion to alter or amend that denial.

Although designated as non‑precedential, the decision is highly instructive on three important points:

  1. The stringent standards governing coram nobis relief in the Tenth Circuit and its interaction with the doctrine of procedural default;
  2. The proper understanding of federal subject‑matter jurisdiction in criminal tax cases under 18 U.S.C. § 3231, independent of debates over the constitutional characterization of income taxes;
  3. The limited impact of the Supreme Court’s decision in Moore v. United States, 602 U.S. 572 (2024), on criminal tax prosecutions and on prior Tenth Circuit precedent such as United States v. Collins, 920 F.2d 619 (10th Cir. 1990).

The case also illustrates how courts handle “tax protester” or “sovereign citizen” style arguments, particularly when advanced belatedly through extraordinary post‑conviction mechanisms.

II. Background of the Case

A. Parties and Charges

The United States charged Craig R. Walcott with:

  • Attempting to evade income tax, in violation of 26 U.S.C. § 7201; and
  • Failing to file an individual income tax return, in violation of 26 U.S.C. § 7203.

These are standard criminal tax provisions:

  • 26 U.S.C. § 7201 – felony tax evasion (willful attempt to evade or defeat any tax);
  • 26 U.S.C. § 7203 – misdemeanor willful failure to file a return, supply information, or pay tax.

B. District Court Proceedings

During the underlying criminal case:

  • Walcott challenged the district court’s subject‑matter jurisdiction, arguing the federal court lacked constitutional authority to enforce federal income taxes against him.
  • Those arguments were rejected.
  • He then entered a plea agreement and pleaded guilty to one count of attempting to evade income tax under § 7201.
  • He was sentenced to three years’ imprisonment and three years’ supervised release.

He did not file a direct appeal of the conviction or sentence.

Later, while still “in custody” (within the meaning of federal post‑conviction law), he filed a motion under 28 U.S.C. § 2255 alleging ineffective assistance of counsel. That § 2255 motion did not raise the jurisdictional arguments he later advanced, and it was denied.

C. Post‑Sentence Collateral Attack and Coram Nobis

In 2024, after completing both imprisonment and supervised release, Walcott filed a new motion “to vacate the judgment for lack of subject‑matter jurisdiction.” Because he was no longer in custody, § 2255 relief was unavailable. The district court therefore construed his filing as a petition for a writ of coram nobis.

Walcott argued, in substance:

  1. The United States had to identify the specific constitutional taxing power (e.g., Article I, § 8 or the Sixteenth Amendment) and the precise tax being enforced to establish the court’s jurisdiction.
  2. The record lacked a “proper declaration” of this alleged constitutional foundation, which he called a “plain fatal error” rendering the judgment void.
  3. As a result, his plea agreement and judgment should be set aside for lack of jurisdiction.

The district court denied the motion in a minute order, characterizing the arguments as “tax protestor characterizations of the law and Constitution that are frivolous,” and reiterating that its jurisdiction was “proper, legal and constitutional.”

D. Motion to Alter or Amend and Reliance on Moore

Walcott then filed a motion to alter or amend, which the district court treated as a Rule 59(e) motion (despite a reference to Rule 52(b)). This motion introduced a new argument based on the Supreme Court’s then‑recent decision in Moore v. United States, 602 U.S. 572 (2024).

According to Walcott:

  • Moore classifies federal income taxes as “indirect taxes” authorized by Article I, § 8 of the Constitution.
  • The government and the district court had relied on United States v. Collins, 920 F.2d 619, 629 (10th Cir. 1990), which stated that the Sixteenth Amendment authorizes “a non-apportioned direct income tax on United States citizens throughout the nation, not just in federal enclaves.”
  • He contended that Moore abrogated Collins and that, because the court allegedly proceeded under a now‑invalid understanding of the Sixteenth Amendment, the court lacked subject‑matter jurisdiction to prosecute him.

The district court granted the Rule 59(e) motion only in the limited sense of issuing a fuller explanation of its reasoning, but it left the denial of relief intact. It held:

  • It had properly construed the earlier motion as a coram nobis petition.
  • The coram nobis petition was procedurally defaulted because the arguments were not raised on direct appeal or in the § 2255 proceeding.
  • Coram nobis is an “extraordinary remedy” reserved for “extraordinary cases,” and this was not such a case.
  • Nothing in Moore invalidated the Internal Revenue Code, the provisions applied to Walcott, or his statute of conviction (§ 7201).

E. Appeal to the Tenth Circuit

Walcott, now proceeding pro se, appealed the denial of coram nobis relief and the denial (in substance) of the motion to alter or amend. The Tenth Circuit:

  • Exercised jurisdiction under 28 U.S.C. § 1291;
  • Submitted the case on the briefs without oral argument (Fed. R. App. P. 34(a)(2));
  • Issued an unpublished order and judgment affirming.

III. Summary of the Opinion

The Tenth Circuit’s decision in United States v. Walcott can be summarized in three core holdings:

  1. Procedural Default Bars Coram Nobis Relief Walcott’s jurisdictional claims were procedurally defaulted because he failed to raise them on direct appeal or in his prior § 2255 motion. Absent the traditional exceptions (e.g., cause and prejudice, actual innocence), such a coram nobis petition must be rejected when the claims could have been raised earlier.
  2. No Defect in Subject‑Matter Jurisdiction Even if the court reached the merits, there was no jurisdictional defect. Under 18 U.S.C. § 3231, district courts have subject‑matter jurisdiction over all federal criminal offenses. Because Walcott was indicted for federal crimes (26 U.S.C. §§ 7201 and 7203), the district court had jurisdiction regardless of constitutional debates over the nature of the income tax.
  3. Moore v. United States Does Not Undermine Criminal Tax Jurisdiction or Walcott’s Conviction Moore, a civil case upholding the constitutionality of the Mandatory Repatriation Tax, does not invalidate the Internal Revenue Code, the provisions applicable to Walcott, or § 7201. It does not call into question the federal courts’ jurisdiction over prosecutions for tax evasion. The Tenth Circuit cited its own recent unpublished decision in United States v. Cromar to reinforce this conclusion.

Accordingly, the Tenth Circuit affirmed the district court’s denial of coram nobis relief and found no abuse of discretion in the denial of the motion to alter or amend.

IV. Detailed Analysis

A. Precedents and Authorities Cited

The panel grounded its reasoning in a mix of Tenth Circuit and out‑of‑circuit precedents, plus Supreme Court authority. The key citations have distinct functions.

1. Liberal Construction of Pro Se Filings – Yang v. Archuleta

The court noted that because Walcott proceeded pro se, his arguments were liberally construed but the court would not act as his advocate, citing Yang v. Archuleta, 525 F.3d 925, 927 n.1 (10th Cir. 2008). This is a standard Tenth Circuit reminder:

  • Pro se filings are read generously; but
  • The court does not invent arguments or supply legal theories the litigant has not advanced.

2. Nature of Coram Nobis – Klein v. United States and United States v. Miles

Two leading Tenth Circuit cases define coram nobis:

  • Klein v. United States, 880 F.2d 250 (10th Cir. 1989) The court emphasized that although the writ has been abolished in civil actions, it “retains its vitality in criminal proceedings,” but only in extraordinary circumstances. - Coram nobis permits collateral attacks by persons no longer in custody who thus cannot use § 2255 or § 2241. - It is available only to correct errors that result in a “complete miscarriage of justice.”
  • United States v. Miles, 923 F.3d 798 (10th Cir. 2019) Miles clarified:
    • Coram nobis “provides a way to collaterally attack a criminal conviction for a person who is no longer ‘in custody’ and therefore cannot seek habeas relief under § 2255 or § 2241.”
    • Claims that were or could have been raised on direct appeal, in a § 2255 motion, or in prior collateral proceedings are generally barred.
    • Absent traditional grounds excusing successive or abusive habeas petitions (e.g., cause and prejudice, actual innocence), such claims cannot be re‑packaged as coram nobis.

The Walcott panel heavily relied on these principles to reject the coram nobis petition on procedural grounds.

3. Standard of Review – Out‑of‑Circuit Guidance

The Tenth Circuit cited several other circuits for the standard of review applicable to coram nobis denials:

  • United States v. Lesane, 40 F.4th 191 (4th Cir. 2022) – reviewing:
    • factual findings for clear error,
    • legal conclusions de novo, and
    • the ultimate decision to grant or deny the writ for abuse of discretion.
  • United States v. Mandanici, 205 F.3d 519 (2d Cir. 2000) – similar bifurcated standard (legal questions de novo; ultimate denial for abuse of discretion).
  • Blanton v. United States, 94 F.3d 227 (6th Cir. 1996) – de novo review of legal issues; clear error for factual findings.

While the Tenth Circuit does not explicitly state it is formally adopting these standards as binding circuit law, by quoting them and then applying them, the panel effectively aligns Tenth Circuit practice with that consensus approach.

4. Review of Rule 59(e) Motions – Burke v. Regalado

The panel cited Burke v. Regalado, 935 F.3d 960, 1044 (10th Cir. 2019), for the proposition that the denial of a motion to alter or amend (Rule 59(e)) is reviewed for abuse of discretion. This is standard law: a district court has broad discretion to reconsider its own orders, and appellate courts overturn such rulings only when they are arbitrary, irrational, or clearly erroneous.

5. Subject‑Matter Jurisdiction in Federal Criminal Cases – 18 U.S.C. § 3231 and United States v. Hopson

On the jurisdiction question, the panel turned to:

  • 18 U.S.C. § 3231 – the statute that confers federal criminal jurisdiction: “The district courts of the United States shall have original jurisdiction, exclusive of the courts of the States, of all offenses against the laws of the United States.”
  • United States v. Hopson, 150 F.4th 1290, 1298 (10th Cir. 2025) – recent Tenth Circuit authority reaffirming that § 3231 grants district courts subject‑matter jurisdiction over federal crimes.

This statutory basis, rather than any particular tax theory, is what matters for jurisdictional purposes.

6. Tax Power and the Sixteenth Amendment – United States v. Collins and Moore v. United States

Two key cases sit in the background of Walcott’s substantive argument:

  • United States v. Collins, 920 F.2d 619, 629 (10th Cir. 1990) – in rejecting a common tax‑protester claim, Collins stated: “[T]he sixteenth amendment authorizes a non‑apportioned direct income tax on United States citizens throughout the nation, not just in federal enclaves.” This statement is routinely cited in the Tenth Circuit to confirm the constitutionality of the federal income tax and refute “federal enclave” theories.
  • Moore v. United States, 602 U.S. 572 (2024) – a Supreme Court decision upholding the Mandatory Repatriation Tax (“MRT”) imposed by 26 U.S.C. § 965. - Moore addressed whether the MRT is a constitutional tax, engaging with questions about realization and the direct/indirect tax distinction. - In the opinion’s text (as quoted by Walcott and the panel), the Court observed that income taxes are indirect taxes authorized by Article I, § 8.

Walcott attempted to argue that Moore “abrogated” Collins, such that the Tenth Circuit’s prior reliance on the Sixteenth Amendment for an unapportioned “direct” tax is no longer correct, thereby supposedly eliminating the court’s criminal jurisdiction. The panel explicitly rejected that inference.

7. Post‑Moore Criminal Tax Challenge – United States v. Cromar

The panel also cited an unpublished Tenth Circuit decision:

  • United States v. Cromar, No. 25‑4002, 2025 WL 2502143 (10th Cir. Sept. 2, 2025) – where the court had already rejected a similar attempt to use Moore to challenge the district court’s jurisdiction in a direct appeal from criminal tax convictions.

By invoking Cromar, the court signals that Moore-based “jurisdictional” attacks on criminal tax cases are an emerging but unavailing line of argument in the Tenth Circuit.

B. The Court’s Legal Reasoning

1. Coram Nobis as an Extraordinary and Narrow Remedy

The panel reaffirms a strict view of coram nobis:

  • It is available only when the petitioner is no longer “in custody” and cannot pursue § 2255 or § 2241 relief.
  • It is an “extraordinary remedy” reserved for “extraordinary cases,” and is available only to correct errors resulting in a “complete miscarriage of justice.”
  • It does not provide a second chance to raise arguments that were or could have been presented on direct appeal or in earlier collateral attacks.

The court applies these principles in a two‑step fashion:

  1. Classification of the Motion – It accepts the district court’s treatment of Walcott’s 2024 filing as a coram nobis petition, since he had completed his sentence.
  2. Procedural Default – It then applies the doctrine (developed in Miles) that coram nobis may not resuscitate claims that could have been raised earlier.

Key to the reasoning is the emphasis that the writ “continues litigation after final judgment and exhaustion of other remedies.” To allow litigants to save arguments for a later coram nobis petition would undermine the finality of criminal judgments.

2. Procedural Default: Claims That “Could Have Been Raised”

The panel’s application of procedural default is straightforward but significant:

  • Walcott did not file a direct appeal at all.
  • In his § 2255 motion, he alleged ineffective assistance of counsel but did not raise the jurisdictional challenge he now presses.
  • He did not explain why he failed to raise that challenge either on direct appeal or in the § 2255 proceedings.

Under Miles, “absent those traditional grounds that have excused successive or abusive habeas petitions, a petition for coram nobis must be rejected if the claim was raised or could have been raised on direct appeal, through a § 2255 motion, or in any other prior collateral attack.” Walcott’s jurisdictional theories fall directly within this barrier: the constitutional foundation of the income tax and federal criminal jurisdiction were issues plainly available years earlier.

Notably, the panel does not explicitly discuss the usual exceptions to procedural default (such as cause and prejudice or fundamental miscarriage of justice grounded in innocence), likely because Walcott did not invoke them and because his claim is purely legal, not factual innocence.

The court therefore holds that Walcott’s coram nobis petition is procedurally defaulted, providing an independent ground to affirm the denial of relief.

3. No Jurisdictional Defect Even on the Merits

The panel goes on to state that, “in any event,” it sees no merit to Walcott’s challenge to subject‑matter jurisdiction. This provides an alternative and reinforcing rationale:

  1. Statutory Basis of Jurisdiction Under 18 U.S.C. § 3231, district courts have original jurisdiction over “all offenses against the laws of the United States.” Because Walcott was indicted under 26 U.S.C. §§ 7201 and 7203, both federal criminal statutes, subject‑matter jurisdiction existed on the face of the indictment.
  2. Constitutional Debates Are Merits, Not Jurisdiction Whether Congress properly exercised its taxing power under Article I, § 8 or the Sixteenth Amendment goes to the validity of the tax laws and perhaps to the merits of a constitutional challenge—not to the existence of federal subject‑matter jurisdiction. Once Congress has enacted a criminal statute and § 3231 confers jurisdiction over “offenses against the laws of the United States,” the court has power to adjudicate the criminal case.
  3. Moore Does Not Alter Jurisdiction The panel emphasizes that Moore:
    • Is a civil case concerning the Mandatory Repatriation Tax;
    • Upheld the tax’s constitutionality, rather than limiting or invalidating Congress’s taxing power; and
    • Did not call into question the validity of the Internal Revenue Code generally, the provisions applicable to Walcott, or § 7201.
    Thus, it has no bearing on the district court’s criminal jurisdiction over Walcott’s prosecution.
  4. Consistency with Cromar By citing United States v. Cromar, the panel signals that this is now settled (at least persuasively) Tenth Circuit reasoning: Moore does not provide a jurisdictional escape hatch for criminal tax defendants.

In effect, the panel rejects the premise that any shift in the Supreme Court’s articulation of the income tax’s constitutional footing could retroactively erase jurisdiction in concluded criminal cases. Even if there were doctrinal evolution, that would not retroactively wipe out the statutory jurisdiction of federal courts in prior prosecutions.

4. Treatment of Moore and Collins

Walcott’s argument hinged on a perceived conflict between:

  • Collins (emphasizing the Sixteenth Amendment’s authorization of a non‑apportioned direct income tax), and
  • Moore (describing income taxes as indirect taxes under Article I, § 8).

The panel does not undertake an extended doctrinal reconciliation between these cases. Instead, it sidesteps the supposed conflict by holding:

  • Whatever Moore says about the classification of taxes, it does not “invalidate[] the Internal Revenue Code generally, the provisions applicable to Walcott in the instant case, or the statute of conviction in the instant case.”
  • Consequently, any tension between Collins and Moore is irrelevant to whether the district court had subject‑matter jurisdiction under § 3231.

In other words, the Constitution allocates taxing power to Congress; once Congress enacts a valid criminal statute enforcing those taxes, the jurisdiction of the district court flows from § 3231, not from the precise labeling of the tax as “direct” or “indirect.” Thus, Walcott’s attempt to transform a nuanced doctrinal question into a jurisdictional “fatal error” fails.

5. Motion to Alter or Amend (Rule 59(e))

Finally, the panel holds that the district court did not abuse its discretion in how it handled the motion to alter or amend:

  • The district court granted the motion only to the extent of providing more detailed reasoning, but left the ultimate result (denial of coram nobis relief) unchanged.
  • Given the clear procedural default and lack of merit, that was well within its discretion under Rule 59(e) as interpreted in Burke v. Regalado.

C. Impact and Significance

1. Reinforcing Finality: Coram Nobis Is Not a Second Habeas or Appeal

The decision reinforces that coram nobis is not a catch‑all mechanism for belatedly raising previously available challenges:

  • Defendants must present constitutional and jurisdictional arguments either on direct appeal or in their first § 2255 motion when they are still in custody.
  • Failure to do so, absent recognized excuses (cause and prejudice, actual innocence), bars later coram nobis petitions raising those same issues.
  • This extends to jurisdictional theories, which some litigants mistakenly believe can be raised at any time without procedural constraint.

Future coram nobis petitioners in the Tenth Circuit will face a steep hurdle if they are attempting to litigate issues they could have raised earlier, even if they try to dress those issues as “jurisdictional.”

2. Clarifying the Role of 18 U.S.C. § 3231 in Criminal Tax Cases

The decision underscores a crucial distinction:

  • Subject‑matter jurisdiction in federal criminal cases is conferred by § 3231 whenever an indictment alleges a violation of federal criminal law.
  • Constitutional arguments about the validity of the underlying statute—or about Congress’s taxing power—are treated as merits questions, not as jurisdictional defects.

This has significant implications for litigants who attempt to circumvent procedural bars by labeling their challenges as jurisdictional. Under Walcott, simply invoking the word “jurisdiction” does not transform a merits issue into one that escapes default or may be raised at any time.

3. Limiting the Reach of Moore v. United States

Moore has sparked substantial academic and litigation interest concerning the scope of Congress’s taxing power. Walcott clarifies its limited impact in at least two respects:

  1. No Retroactive Jurisdictional Consequences The Tenth Circuit rejects the notion that Moore retroactively undermines existing criminal tax convictions or deprives district courts of jurisdiction in such cases.
  2. No Broad Invalidations of the Internal Revenue Code The court states flatly that nothing in Moore invalidates the Code generally or the specific provisions under which Walcott was convicted.

For practitioners, this signals that attempts to invoke Moore as a wide‑ranging attack on the federal tax system are unlikely to succeed, at least in the Tenth Circuit.

4. Continued Judicial Rejection of “Tax Protester” Theories

The district court explicitly characterized Walcott’s arguments as “tax protestor characterizations of the law and Constitution that are frivolous,” and the Tenth Circuit did not dispute that description. This fits into a long line of cases dismissing such arguments, including:

  • Claims that the federal income tax is unconstitutional;
  • Assertions that only residents of federal enclaves are subject to federal tax laws;
  • Efforts to reframe substantive or constitutional challenges as jurisdictional defects.

Walcott thus contributes to the Tenth Circuit’s consistent message: these theories not only fail on the merits, they will also be barred when proffered belatedly through extraordinary writs.

V. Complex Concepts Simplified

Several legal concepts in the opinion can be opaque to non‑lawyers. The following explanations may help clarify them.

1. What Is a Writ of Error Coram Nobis?

Coram nobis is an ancient common‑law writ that survives in limited form for criminal cases. It:

  • Is used by someone who has already completed their sentence and is no longer “in custody,” so they cannot use the usual post‑conviction tools (like § 2255).
  • Allows them to seek to set aside a conviction for very serious, fundamental errors that render the proceedings invalid.
  • Is considered “extraordinary” and is granted only in rare cases where there has been a “complete miscarriage of justice.”

It is not a general second appeal, second habeas petition, or a way to re‑argue issues that could have been raised earlier.

2. What Is Procedural Default?

“Procedural default” is a doctrine that bars a defendant from raising certain claims in later collateral proceedings if:

  • They could have raised the claim on direct appeal or in a timely § 2255 motion, but did not; and
  • They cannot show a valid excuse (such as cause for the default and prejudice, or actual innocence).

The idea is to encourage defendants to raise all their claims promptly and to protect the finality of criminal convictions. Walcott applies this doctrine to coram nobis petitions in the same way it applies to habeas petitions.

3. What Is Federal Subject‑Matter Jurisdiction in Criminal Cases?

“Subject‑matter jurisdiction” refers to a court’s legal authority to hear a type of case. In federal criminal law:

  • Congress enacts criminal statutes defining federal crimes (e.g., 26 U.S.C. § 7201).
  • 18 U.S.C. § 3231 grants federal district courts jurisdiction over “all offenses against the laws of the United States.”

Thus, if:

  • The indictment charges a violation of a valid federal criminal statute, and
  • The case is filed in a federal district court,

the court has subject‑matter jurisdiction. Whether the statute is constitutional, or whether the facts fit the statute, goes to the merits—not to jurisdiction.

4. Direct vs. Indirect Taxes; Article I vs. the Sixteenth Amendment

The Constitution distinguishes between:

  • Direct taxes – historically requiring apportionment among the states by population; and
  • Indirect taxes (duties, imposts, excises) – requiring uniformity but not apportionment.

The Sixteenth Amendment provides that Congress can “lay and collect taxes on incomes, from whatever source derived, without apportionment among the several States.” Courts have debated whether certain taxes are “direct” or “indirect,” and what role realization plays.

However, Walcott makes clear that these doctrinal questions:

  • Do not undermine the general validity of criminal tax statutes like § 7201;
  • Do not strip federal courts of jurisdiction under § 3231;
  • Cannot be repurposed as late‑stage “jurisdictional” attacks through coram nobis.

5. Why “Tax Protester” Arguments Are Routinely Rejected

Courts use the term “tax protester” (sometimes “tax defier”) to describe a constellation of arguments asserting, for example:

  • That the federal income tax is inherently unconstitutional;
  • That only residents of federal territories or enclaves are subject to federal tax law;
  • That the IRS or federal courts lack authority over ordinary citizens’ income.

These arguments have been rejected repeatedly by every federal circuit for decades. Courts now sometimes label them “frivolous,” meaning they have no arguable basis in law. Walcott fits this pattern: once the arguments are characterized as tax‑protester in nature, they are handled summarily.

VI. Conclusion: Key Takeaways and Broader Significance

United States v. Walcott is a compact but illuminating decision that reinforces several important principles in federal post‑conviction and tax law:

  1. Coram Nobis Is Strictly Limited – It is available only to correct fundamental miscarriages of justice for individuals no longer in custody. It cannot resuscitate claims that could have been litigated on direct appeal or via § 2255.
  2. Procedural Default Applies to Jurisdiction‑Labeled Claims – Simply calling a claim “jurisdictional” does not exempt it from procedural default. If the issue could have been raised earlier, coram nobis is not available absent traditional exceptions.
  3. Federal Criminal Jurisdiction Rests on § 3231 – Once Congress creates a federal criminal offense and § 3231 confers jurisdiction over “offenses against the laws of the United States,” district courts have subject‑matter jurisdiction. Debates over the constitutional source of the tax power do not negate that jurisdiction.
  4. Moore v. United States Has Limited Reach in Criminal Tax Contexts – Moore does not invalidate the Internal Revenue Code, does not undermine the criminal tax statutes, and does not strip federal courts of jurisdiction in tax prosecutions. Attempts to weaponize Moore for sweeping collateral attacks on prior convictions are unlikely to succeed.
  5. Tax Protester Arguments Remain Non‑Starters – The Tenth Circuit continues to treat tax‑protester‑style constitutional theories as frivolous. When such theories are raised late and wrapped in “jurisdictional” language, they are doubly barred—both on the merits and by procedural default.

Although the Walcott order and judgment is not binding precedent, it is a clear, persuasive statement of the Tenth Circuit’s current approach to coram nobis, criminal jurisdiction under § 3231, and the limited effects of Moore on federal tax enforcement. For practitioners, it serves as both a warning against overreading Moore and a roadmap for understanding the procedural and jurisdictional defenses that protect the finality of federal criminal tax convictions.

Case Details

Year: 2025
Court: Court of Appeals for the Tenth Circuit

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