Specific Sentencing Guidelines Recommendations. With respect to the application of the Sentencing Guidelines to the defendant’s conduct, the parties agree to recommend as follows:
Specific Sentencing Guidelines Recommendations. With respect to the application of the Sentencing Guidelines to the defendant’s conduct, the parties agree to recommend as follows: • Defendant's offense resulted in a tax loss of not more than $1,800,000.00. Defendant retains the right to argue that the loss amount is less than $1,800,000.00. Defendant understands that this recommendation is not binding upon the Court or the United States Probation Office, which may make different findings as to the application of the Sentencing Guidelines to the defendant’s conduct. The defendant also understands that the United States will provide the Court and the United States Probation Office all information in its possession which it deems relevant to the application of the Sentencing Guidelines to the defendant’s conduct.
Specific Sentencing Guidelines Recommendations. With respect to the application of the Sentencing Guidelines to the defendant’s conduct, the parties agree to recommend that the loss amount for purposes of determining the defendant’s applicable Sentencing Guidelines range, pursuant to U.S.S.G. § 2B1.1, is $242,975.89 and that a two-level enhancement under U.S.S.G. § 3B1.3 shall apply due to the defendant’s abuse of a position of trust. Accordingly, the parties agree that the appropriate Sentencing Guidelines offense level, prior to any reduction for acceptance of responsibility, is 19. Each party reserves the right to make whatever remaining arguments it deems appropriate with regard to departures or variances. The defendant understands that any recommendations are not binding upon either the Court or the United States Probation Office, which may make different findings as to the application of the Sentencing Guidelines to the defendant’s conduct. The defendant further understands that the United States will provide the Court and the United States Probation Office all information in its possession that it deems relevant to the application of the Sentencing Guidelines to the defendant’s conduct.
