CARDAMONE, Circuit Judge:
This appeal from a sentence following a judgment of conviction in a criminal case asks us to determine whether "sophisticated means" were used to impede discovery of a tax-evasion scheme. See United States Sentencing Commission, Guidelines Manual § 2T1.1(b)(2) (Nov. 1992) (U.S.S.G. or Guidelines). In light of our decision today in United States v. Lewis,
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