United States Fourth Circuit

Convictions and sentences arising from a tax evasion scheme in which defendants, former co-pastors of a church, omitted millions of dollars of taxable income from their jointly filed tax returns, are affirmed where: 1) the evidence did support a willful blindness instruction; 2) the district court did not err in including the tax losses for 1991-1993 in defendant's restitution amount; 3) the court correctly imposed a two-level enhancement under U.S.S.G. section 2T1.1(b)(2) for their use of "sophisticated means", and 4) district court imposed a two-level enhancement under U.S.S.G. section 3B1.3 for defendants' abuse of a position of trust "that significantly facilitated the commission or concealment of the offense."

Appellate Information

• Decided 06/22/2012
• Published 06/22/2012

Judges

• WILKINSON

Court

• United States Fourth Circuit

Counsel