Government’s Sentencing Statement for Defendant Stace Wallace — United States v. Wallace (Dkt. 119, D. Colo.)

Summary

The government's sentencing statement for defendant Stace Wallace in United States of America v. Stace Yater Wallace, Criminal Case No. 22-cr-00211-PAB, in the U.S. District Court for the District of Colorado, filed April 11, 2025 (Document 119). Filed by Assistant United States Attorneys Tim R. Neff and Nicole C. Cassidy, it states that the government has no objection to the presentence report or its recommendation and submits that a 3 year sentence to probation and restitution of $7,759 to the IRS are warranted. It states that the defendant pleaded guilty to willful failure to file a tax return under 26 U.S.C. § 7203, a Class A misdemeanor, relating to personal and business returns and payments for 2017-19.

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Case No. 1:22-cr-00211-PAB       Document 119       filed 04/11/25    USDC Colorado          pg 1
                                          of 3




                       IN THE UNITED STATES DISTRICT COURT
                           FOR THE DISTRICT OF COLORADO

 Criminal Case No. 22-cr-00211-PAB

 UNITED STATES OF AMERICA,

        Plaintiff,

 v.

 2.     STACE YATER WALLACE,

                Defendant.


             GOVERNMENT’S SENTENCING STATEMENT FOR DEFENDANT
                             STACE WALLACE


        The United States of America, by and through J. Bishop Grewell, Acting United

 States Attorney for the District of Colorado, Tim R. Neff and Nicole C. Cassidy,

 Assistant United States Attorneys, files this Sentencing Statement for Defendant Stace

 Wallace.

        As a threshold matter, the Government has no objection to the presentence

 report [#104] or its final sentencing recommendation [#104-1].

        The Government submits that a 3 year sentence to probation and an order of

 restitution for $7,759 to the IRS is warranted in this case. As outlined in the

 presentence report, the Defendant’s pled guilty to the offense of Willful Failure to File

 Tax Return in violation of 26 U.S.C. § 7203 which is a Class A Misdemeanor. The

 offense conduct relates to a three year period (2017-19) during which the Defendant did

 not timely file personal and business returns nor make timely payments to the IRS for


                                              1

Case No. 1:22-cr-00211-PAB       Document 119      filed 04/11/25   USDC Colorado       pg 2
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 taxes due and owing. PSR, ¶¶ 9-13. As noted above, the total loss to the IRS is

 minimal. The Defendant has no criminal history.

        The Government adopts and incorporates the PSR’s justification for such a

 recommended sentence. PSR, Exhibit A, R-1 [#104-1]. As noted therein, “Up until the

 instant offense, the defendant had lived what appears to be a law-abiding life.” Id.

 at R-4.

        The Government maintains that a 3 year probationary sentence will adequately

 address the sentencing factors set forth under Title 18, U.S.C. § 3553(a)(1).

        WHEREFORE, the Government requests that the Court sentence the Defendant

 as recommended above.

        Respectfully submitted this 11th day of April, 2025.

                                    J. BISHOP GREWELL
                                    Acting United States Attorney

                                    By: s/ Tim Neff
                                       Tim Neff
                                       Assistant U.S. Attorney
                                       United States Attorney’s Office
                                       1801 California Street, Suite 1600
                                       Denver, Colorado 80202
                                       Telephone: (303) 454-0367
                                       Fax: (303) 454-0401
                                       Email: Tim.Neff@usdoj.gov
                                       Attorney for Government

                                    By: s/ Nicole C. Cassidy
                                       Nicole C. Cassidy
                                       Assistant U.S. Attorney
                                       United States Attorney’s Office
                                       1801 California Street, Suite 1600
                                       Denver, Colorado 80202
                                       Telephone: (303) 454-0100
                                       Email: nicole.cassidy@usdoj.gov

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Case No. 1:22-cr-00211-PAB            Document 119        filed 04/11/25     USDC Colorado      pg 3
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                                   CERTIFICATE OF SERVICE

         I certify that on this 11th day of April, 2025, I electronically filed the foregoing

 GOVERNMENT’S SENTENCING STATEMENT FOR DEFENDANT STACE

 WALLACE with the Clerk of the Court using the CM/ECF system which will send notification

 of such filing to all counsel of record in this case.


                                         By: s/Maureen Carle
                                             Legal Administrative Specialist
                                             United States Attorney=s Office




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