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NOTES 339 Tax Lawyer, Vol. 55, No. 1 NOTE RECENT DEVELOPMENTS IN THE FEDERAL SENTENCING GUIDELINES FOR TAX EVASION: UNITED STATES V. THOMAS AND CONSTANCE TWIEG In United States v. Twieg,1 the United States Court of Appeals for the Seventh Circuit upheld the district court’s sentencing of Thomas and Constance Twieg (the “taxpayers”) for tax evasion. In its calculation of the taxpayers’ sentences under the Federal Sentencing Guidelines (“Guidelines”),2 the Eastern District of Wisconsin included the...