Set base offense level and special offense characteristics (SOCs).

Selected Guideline: 2T1.4 - Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud

Level Level from §2T4.1 (Tax Table) corresponding to the tax loss

if there is no tax loss

Level 6

Total Offense Level:Level from §2T4.1 (Tax Table) corresponding to the tax loss

Statutory Provisions:

Special Offense Characteristics:

Check the characteristics that apply to calculate the total offense level.

If (A) the defendant committed the offense as part of a pattern or scheme from which he derived a substantial portion of his income; or (B) the defendant was in the business of preparing or assisting in the preparation of tax returns

+2 levels

If the offense involved sophisticated means

+2 levels

Note: If the resulting offense level is less than level 12, increase to level 12.

Chapter 2 Adjustments

Selected Guideline: 2T1.4 - Aiding, Assisting, Procuring, Counseling, or Advising Tax Fraud

Statutory Provisions:

Special Offense Characteristics: