Grunewald v. United States

Grunewald (defendant) used his influence with a Bureau of Internal Revenue official to obtain "no prosecution" rulings for two companies under tax-fraud investigation, in exchange for a large fee, and he and others later worked to conceal their scheme. Grunewald and two others were indicted for conspiracy to defraud the United States on October 25, 1954; they argued the conspiracy - and the "no prosecution" rulings that fulfilled its purpose - ended before October 25, 1951, three years before the indictment, making prosecution time-barred. The government argued the later concealment efforts kept the conspiracy alive within the limitations period. The court of appeals affirmed the convictions, and the Supreme Court granted certiorari.