United States Ninth Circuit

The district court's application of a two-level "sophisticated means" enhancement to defendants' sentences for tax fraud is affirmed, where: 1) conduct need not involve highly complex schemes or exhibit exceptional brilliance to justify a sophisticated means enhancement; and 2) the defendants' efforts to disguise funds taken for their own personal use as money paid to a third-party vendor for business expenses through use of a bank account with a deceptive name constituted a sufficiently complex method of concealment to warrant application of the sophisticated means enhancement.

Appellate Information

• Decided 04/03/2013
• Published 04/03/2013

Judges

• CLIFTON

Court

• United States Ninth Circuit

Counsel