AMENDMENT 231
The Commentary to §2T1.4 captioned "Application Notes" is amended in Note 2 by deleting:
"Whether ‘sophisticated means’ were employed (§2T1.1(b)(2)) requires a determination similar to that in §2F1.1(b)(2).",
and inserting in lieu thereof:
"‘Sophisticated means,’ as used in §2T1.4(b)(2), includes conduct that is more complex or demonstrates greater intricacy or planning than a routine tax-evasion case.".
Reason for Amendment: The purpose of this amendment is to clarify the commentary.
Effective Date: The effective date of this amendment is November 1, 1989.