Crawford

MEMORANDUM *

Valerie Crawford (“Crawford”), a former officer and employee of the Internal Revenue Service (“IRS”), appeals her convictions under 18 U.S.C. § 371 (conspiracy to defraud the United States) and I.R.C. § 7214(a)(7) (unlawful act by a revenue officer). Crawford contends that the district court made several errors, most of which arise from its characterization of the charged conspiracy as a single conspiracy. Crawford also challenges the district court’s calculation of her base offense level and the court’s determination of the amount of restitution. 1 We affirm Crawford’s convictions and sentence, except *720 that we vacate and remand the restitution order.

The central thread throughout Crawford’s appeal is her contention that there were at least two conspiracies, the first to defraud the government, which conspiracy she asserts ended before 1995, and a separate conspiracy to defraud taxpayer clients of her co-conspirators. She contends that she was a member of only the first conspiracy. We disagree with these contentions. The evidence supports the conclusion that Crawford’s acts, as well as the fraud perpetrated on the third-party taxpayers, were part of one overall…