Whether the court may apply a two-level enhancement for crimes involving ten or more victims when the victim is the Government

QUESTIONS PRESENTED 1. Whether, in determining the sentence for a tax-fraud conspiracy where the defendant is charged with conversion of government property and aggravated identity theft, the court may apply a two-level enhancement for Games involving ten or more victims, when the victim is the Government. 2. Whether, in determining a loss figure for a tax-fraud conspiracy, the court may rely upon evidence that the defendant has shown to be unreliable and not credible. i