United States v. Iovino, No. 14-270 (2d Cir. 2015)
Annotate this CaseDefendant, employed as the property manager of a condominium association, was convicted of wire fraud for embezzling funds from the condominium association and bank fraud for taking out an unauthorized loan in the condominium association's name. The district court applied a four-level sentencing enhancement under U.S.S.G. 2B1.1(b)(2)(B), which applies to offenses involving 50 or more victims. The court affirmed the sentence, concluding that the district court properly counted the individual tenants as victims (more than 70 tenants total) and, therefore, properly applied the enhancement.
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