I previously offered the Government's opening brief in the appeal of the Ty Warner sentencing. See When is Booker Variance Too Much? Per DOJ, Certainly in the Ty Warner Case (Federal Tax Crimes Blog 5/12/14), here.
I offer today Warner's answering brief here.
The brief is very well written, as one would expect from counsel involved, including Paul Clement (ubiquitous Supreme Court and Appellate Counsel) and Mark Matthews (the tax guru). For those interested in Warner and the state of the sentencing court's broad Booker discretion, the brief is a great read. Keep in mind that it is not a disinterested discussion of the law.
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