SENTENCING MEMORANDUM
MILLER, District Judge.
Grama Bhagavan has pleaded guilty to a charge of attempting to evade income tax, and offense carrying a possible term of imprisonment for not more than five years and a fine of not more than $250,000. 26 U.S.C. § 7201. The parties agree on the amounts of unreported income, but dispute several of the matters the court must resolve in determining Mr. Bhagavan's sentencing range. The court adopts as...
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