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1) Cianci pled guilty to two counts of tax evasion for failing to report income from embezzlement and kickbacks on his 1989 and 1990 tax returns. 2) As part of the scheme, Cianci diverted Panasonic merchandise to a company he owned, used falsified invoices and records to conceal the transactions, and received unrecorded cash payments. 3) At sentencing, the court applied a two-level enhancement for sophisticated means based on Cianci

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