Donohoue

*790 MEMORANDUM *

The district court did not err when it applied the “more than minimal planning” and “abuse of trust” enhancements. Donohoue’s criminal behavior continued for a lengthy period of time and was sufficiently sophisticated to qualify as an offense involving “more than minimal planning.” United States v. Lindholm, 24 F.3d 1078, 1086 (9th Cir.1994) (citation omitted). In addition, Donohoue occupied a position of trust with his employer that provided him with “the freedom to commit a difficult-to-detect wrong.” United States v. Medrano, 241 F.3d 740, 746 (9th Cir.2001) (citation omitted).

The district court’s calculation of total loss for restitution purposes was not clearly erroneous. The unauthorized check was properly included in the court’s calculation of total loss as a loss resulting from factors extraneous to Donohoue’s criminal conduct. See United States v. Sarno, 73 F.3d 1470, 1500 (9th Cir.1995). In addition, Donohoue’s tax evasions in 1998 and 1999 were part of the same course of conduct as the 1997 tax evasion charge to which he pled guilty, and were therefore properly included in the total loss calculation for restitution purposes. See Chang v. I.N.S., 307…