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U.S. v. Richman, No. 95-1682 (2nd Cir.) (93 F.3d 1085) (August 28, 1996) (Judge Richard J. Cardamone)

The Second Circuit vacated a sentence imposed by the dictrict court which refused to apply the sophisticated means enhancement of ยง 2T1.1(b)(2) on the grounds that it was the accountants for the defendant - not the defendant - who had engaged in the sophisticated means. The Court rejected that philosophy ...

 

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