United States v. Thomas Jennings

OPINION

CLIFTON, Circuit Judge:

Defendants appeal the application of a two-level enhancement imposed by the district court in determining their sentences following convictions for tax fraud, because their offenses involved “sophisticated means,” under section 2Tl.l(b)(2) of the federal Sentencing Guidelines. 1 We affirm the district court’s application of the enhancement. Conduct need not involve highly complex schemes or exhibit exceptional brilliance to justify a sophisticated means enhancement. Defendants’ effort to conceal income by using a bank account with a deceptive name was…