New more lenient Sentencing Guidelines, effective 11/1/2010. The new / proposed guidelines permit a judge more leeway to consider factors not previously considered considered in the mainstream: criminal defendants’ military service, age, and mental and emotional conditions. Congress could still modify or even rejcect the proposals, but I don't think that is likely.
I think most of the phenomena that led to the change are not prominent in federal tax cases, but there is still some room for skillful and creative lawyering the sentencing phase in these cases.
Some links to further explore the proposals:
Sentencing Commission Proposals
Wall Street Journal Article
Wall Street Journal Law Blog
Sentencing Law Blog
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