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

This is another of a string of recent rulings that suggests it doesn’t take much for a court to find that a defendant has used “sophisticated means” in a tax fraud case to qualify for the two-level sentencing enhancement provided for in U.S.S.G. § 2T1.1(b)(2) (and §§ 2T1.4 and 2T3.1). ...

 

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