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U.S. v. Lewis, No. 95-1681, No. 1514 (2nd Cir.) (93 F.3d 1075) (August 28, 1996) (Judge Richard J. Cardamone)

Here the Court held that district court had erred when it treated the "sophisticated means" provision as a characteristic of the individual defendant rather than as an offense characteristic - and therefore the enhancement should have been applied even if the sophisticated means were employed by the defendant's accounting firm ...

 

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