United States v. Douglas Dale Kienenberger, United States of America v. Douglas Dale Kienenberger

FARRIS, Circuit Judge:

Defendant Douglas Kienenberger appeals his convictions on five counts of willfully attempting to evade federal income taxes in violation of 26 U.S.C. § 7201 and seven counts of falsely representing a social security number in violation of 42 U.S.C. § 408(a)(2). The government cross-appeals, arguing that the district court erred in its application of the Sentencing Guidelines by not including “tax loss” from pre-Guidelines years when it computed defendant’s base offense level. We have jurisdiction of the timely appeal pursuant to 28 U.S.C. § 1291 and 18 U.S.C. § 3742. We…