United States v. Abrams

Motion for downward departure granted, from 12-18 months to six months house arrest, due to extraordinary family circumstances. Defendant, convicted of tax evasion, had a young daughter with an organic brain dysfunction. Mr. Lichtman argued that a sentence of imprisonment and the resultant absence of her father would be devastating to the daughter and the progress she had achieved through psychotherapy and speech therapy. Court described Mr. Lichtman’s submission as “a model of an effective sentencing memorandum.”