Catherine Elizabeth Chollet, aka Liza Chollet, and Michael Elliot Kohn v. United States

In Abouammo v. United States, 608 U. ⁠S. 597 (2026), decided two days after the judgment below, this Court held that venue lies only where the offense’s conduct elements occurred—“the acts that the prosecution must prove to secure a conviction.” Id., at 603. Venue for a standalone offense “must be based on the conduct that [the statute] itself proscribes, not on the conduct another law does.” Id., at 607. Petitioners, two Missouri tax attorneys, prepared the charged returns in Missouri and filed them from Missouri. Yet the Fourth Circuit upheld venue in North Carolina for their convictions under 26 U. ⁠S. ⁠C. § ⁠7206(2). It relied on what taxpayers, an insurance agent, and his office manager did there, and on acts that furthered a separately charged conspiracy. Should the petition be granted, the judgment vacated, and the case remanded for further consideration in light of Abouammo?