U.S. v. Littrice

Dist. Ct. did not err in sentencing defendant to 36-month term of incarceration in prosecution on charge that defendant aided and assisted taxpayers in preparing tax returns that contained materially false and fraudulent information, where Dist. Ct. based sentence in part on calculation of tax loss at "between $400,000 to $1 million" arising out of 662 similar tax returns prepared by defendant. Record contained evidence suggesting clear pattern that taxpayers expected to owe taxes when submitting tax records to defendant for preparation of tax return, but received tax refunds generated from defendant's inclusion of false information not submitted by taxpayers. Gov't. was not required during sentencing proceeding to present evidence from each taxpayer attesting to fact that they were unaware of fraudulent information supplied by defendant. Moreover, Dist. Ct. was not required to give more precise tax loss figure.