Court of Appeals for the Second Circuit August 28, 1996, 1515, Docket 95-1682 (United States v. Harry Richman)

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

§ 2Tl.l(b)(2) (Nov. 1992) (U.S.S.G. or Guidelines). In light of our decision today in

United States v. Lewis,

93 F.