TINDER, Circuit Judge.
A jury convicted LaShawn Littrice of fourteen counts of willfully aiding and assisting in the preparation of tax returns containing materially false and fraudulent claims, including phony medical and business expenses and charitable donations. The evidence at trial proved a tax loss of $31,849. At sentencing, the government proposed a tax loss figure of $1.6 million by identifying 662 returns Littrice prepared that contained materially fraudulent...
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