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U.S. v. Barakat, No. 96-5013 (11th Cir.) (130 F.3d 1448) (December 15, 1997) (Judge Edward E. Carnes)

Case was remanded for a determination of whether the court took into account only conduct directly related to the offense of conviction.

Here the Court held that "unless the use of sophisticated means significantly facilitates the defendant's concealment of his tax evasion from the IRS, it is not relevant conduct ...

 

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