United States v. Steven Hart

BYE, Circuit Judge.

Steven Hart pleaded guilty to one count of income tax evasion in violation of 26 U.S.C. § 7201. The parties agreed the district court would calculate the amount of tax loss to determine the appropriate base offense level under the United States Sentencing Guidelines (U.S.S.G.), and determine whether any special offense characteristics applied. The district court calculated the amount of tax loss at $126,704. The district court also determined Hart’s offense involved sophisticated means and added two levels pursuant to U.S.S.G. § 2T1.1(b)(2). Hart argues on appeal the…