United States v. Robert E. Cseplo

DAVID A. NELSON, Circuit Judge.

Convicted both of willfully underreporting income on his wholly-owned corporation’s federal income tax return (a violation of 26 U.S.C. § 7206(1)) and of willfully attempting to evade individual income taxes by preparing and signing a return that failed to report the receipt of sums skimmed from the corporation (a violation of 26 U.S.C. § 7201), the defendant was sentenced to imprisonment for a term of four months. He now appeals his sentence, contending, among other things, that in calculating the “tax loss” under the sentencing guidelines the district court…