United States v. Ephraim Lewis
Court of Appeals for the Second Circuit
1Opinion of the Court
CARDAMONE, Circuit Judge:
This appeal by the United States in a criminal sentencing case asks us to determine whether “sophisticated means” were used to impede discovery of a tax-evasion scheme. See United States Sentencing Guidelines § 2T1.1(b)(2). This is our first occasion to interpret this provision of the Guidelines.
Courts are frequently asked to interpret broad phrases that defy precise definition. Such phrases are often expressed at a high level of generality, and a “mechanical jurisprudence” will not help define them. “Sophisticated means” is one such open-ended phrase. We are not…
2Cases cited31 opinions
- Koon v. United StatesSupreme Court of the United States · 1996
- Stinson v. United StatesSupreme Court of the United States · 1993
- Bowles v. Seminole Rock & Sand Co.Supreme Court of the United States · 1945
- United States v. Rusel J. Jagim, United States of America v. Jay L. Depew, United States of America v. Jay L. Depew, United States of America v. Sylvester A. Ziebarth, Sylvester A. Ziebarth v. United StatesCourt of Appeals for the Eighth Circuit · 1992
- Compañia General De Tabacos De Filipinas v. Collector of Internal RevenueSupreme Court of the United States · 1927
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3Cited by65 opinions
- United States v. Tin Yat Chin, AKA Tan C. DauCourt of Appeals for the Second Circuit · 2004
- United States v. Douglas BrownCourt of Appeals for the Second Circuit · 1996
- United States v. VizcarraCourt of Appeals for the Seventh Circuit · 2012
- United States v. Thomas B. Middlemiss, William Orfanos and Setiri SotiriouCourt of Appeals for the Second Circuit · 2000
- United States v. BarakatCourt of Appeals for the Eleventh Circuit · 1997
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