Tawil

MEMORANDUM *

Joseph Tawil and Ramzi Tawil appeal their convictions and sentences for conspiracy to defraud and obstruct the United States, and in particular the Internal Revenue Service. See 18 U.S.C. § 371 . We affirm the convictions and affirm in part, vacate in part and remand as to sentencing and restitution.

(1) Both Joseph and Ramzi claim that the district court erred when it admitted evidence regarding the frauds they perpetrated on taxpayers as part of then-conspiracy. They claim that the evidence was not relevant to their fraud upon the IRS. We disagree because, contrary to their assertions, the frauds upon the taxpayers were part and parcel of the scheme to divert funds otherwise available (and supposedly destined) for tax payments and to obstruct the government from collecting those and other funds from the taxpayers. The evidence was relevant, even central, to proving up the conspiracy’s goal to obstruct and defraud its target, the United States. See Tanner v. United States, 483 U.S. 107, 130 , 107 S.Ct. 2739, 2752 , 97 L.Ed.2d 90 (1987); Ingram v. United States, 360 U.S. 672, 679-80 , 79 S.Ct. 1314, 1320 , 3 L.Ed.2d 1503 (1959); United States v. Caldwell, 989 F.2d…