MEMORANDUM OPINION
HANEN, District Judge.
On the 8th day of March, 2004, came to be heard the final sentencing hearing on the above referenced case. Gustavo and Francisco Ledesma ("the defendants") pleaded guilty to a violation of Title 18 U.S.C. § 371 — conspiracy to defraud the United States by preparation of false tax returns. Both the Government and the defendants objected to the section of the Presentence Investigation Report ("PSI") that...
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