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U.S. v. Jennings, No. 11-50315 (9th Cir.) (711 F.3d 1144) (April 3, 2013) (Judge Richard R. Clifton)

Here the Court approved a two-level enhancement for “sophisticated means” in a tax fraud case, after concluding that the offense conduct “need not involve highly complex schemes or exhibit exceptional brilliance" to justify the enhancement.

This is another of a string of recent rulings that suggests it doesn’t take much ...

 

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