Adjustments to the offense level are determined based on the defendant’s conduct.
A defendant may receive a reduction to their offense level if they are willing to admit responsibility for the offense before trial and accept a plea bargain.
Reductions may also be warranted if a defendant is determined to have played only a minor role in the tax crime or if the defendant can successfully argue that multiple counts should be grouped into a single offense.
The court also has the discretion to apply adjustments to increase the criminal history level. This could be warranted by the determination that an individual, or group of individuals, used “sophisticated means” in carrying out or covering up a crime.
Additionally, courts have the discretion to increase the base level offense if a person is determined to have obtained a significant portion of their income through criminal means, through extortion or coercion, or by assisting others in violating the tax code.