Metteer

MEMORANDUM **

We affirm the District Court’s denial of Metteer’s motion to dismiss the indictment as to the 26 U.S.C. § 7212 (a) violation.

The indictment sufficiently alleged all of the essential elements of a § 7212(a) offense. 1 The indictment sufficiently alleged the particular methods Metteer used to “corruptly ... endeavor to obstruct or impede the due administration of [the tax laws].” 2 The indictment alleged that “[ajware of Internal Revenue Service inquiries into his tax liability,” Metteer corruptly endeavored to obstruct and impede the due administration of the tax laws by actively trying to hide his interest in income and assets through misleading means. This language, in the context of the rest of the indictment, alleged a suffi *136 cient nexus between the corrupt endeavor and the due administration of the tax laws.

The indictment also was not insufficient for failing to allege that Metteer intended to improperly influence a government official because § 7212(a) imposes no such requirement. Nor did the indictment fail because the conduct it alleged was private, lawful, financial conduct that cannot constitute corrupt obstruction of the due administration of the…