"In reviewing a sentence for procedural error, we review the district court's factual findings for clear error and its application of the guidelines de novo." United States v. Barker, 556 F.3d 682, 689 (8th Cir. 2009). We review the sentence imposed for abuse of discretion.

We review the reasonableness of sentences in two parts: first, for significant procedural error, and second, if there is no significant procedural error, for substantive reasonableness. United States v. Barker , 556 F.3d 682, 689 (8th Cir. 2009). "Procedural error includes ... failing to adequately explain the chosen sentence—including an explanation for any deviation from the Guidelines range."

"In reviewing a sentence for procedural error, we review the district court's factual findings for clear error and its application of the guidelines de novo." United States v. Barker, 556 F.3d 682, 689 (8th Cir. 2009).

"In reviewing a sentence for procedural error, we review the district court's factual findings for clear error and its application of the guidelines de novo." United States v. Barker, 556 F.3d 682, 689 (8th Cir. 2009).

"In reviewing a sentence for procedural error, we review the district court's factual findings for clear error and its application of the guidelines de novo." United States v. Barker, 556 F.3d 682, 689 (8th Cir. 2009).

"In reviewing a sentence for procedural error, we review the district court's factual findings for clear error and its application of the guidelines de novo." United States v. Quiver, 925 F.3d 377, 380 (8th Cir. 2019) (quoting United States v. Barker, 556 F.3d 682, 689 (8th Cir. 2009) ). "Our review of the substantive reasonableness of a sentence for abuse of discretion is highly deferential." Id. (quoting United States v. Cole, 765 F.3d 884, 886 (8th Cir. 2014) ).

"In reviewing a sentence for procedural error, we review the district court’s factual findings for clear error and its application of the guidelines de novo." United States v. Barker , 556 F.3d 682, 689 (8th Cir. 2009). "Our review of the substantive reasonableness of a sentence for abuse of discretion is highly deferential."

On de novo review, this court affirms the conviction for tax evasion, because the government proved a tax deficiency, willfulness, and affirmative acts constituting evasion. See United States v. Olsen, 760 F.3d 825, 827 (8th Cir. 2014) (sufficiency of evidence to sustain conviction is reviewed de novo; this court views the evidence in the light most favorable to the government, resolves conflicts in the government's favor, and accepts all reasonable inferences that support the verdict); United States v. Renner, 648 F.3d 680, 688 (8th Cir. 2011) (elements of tax evasion under 26 U.S.C. § 7201); United States v. Pomponio, 429 U.S. 10, 12 (1976) ("willfully" in the context of tax crimes means a "voluntary, intentional violation of a known legal duty"); United States v. Barker, 556 F.3d 682, 688 (8th Cir. 2009) (finding a reasonable jury could conclude that a defendant's attempts to place his assets "beyond the reach of the IRS" demonstrated knowledge of the duty to pay federal income taxes). This court also affirms Pearson's conviction for wire fraud.

6. Sentencing Guidelines Calculations and Reasonableness of Sentences We review a district court’s factual findings pertaining to the calculation of the applicable United States Sentencing Guidelines ("U.S.S.G." or "Guidelines") range for clear error and its application of the Guidelines de novo . United States v. Hairy Chin, 850 F.3d 398, 402 (8th Cir. 2017) (quoting United States v. Barker, 556 F.3d 682, 689 (8th Cir. 2009) ). If we find no error, we review the sentence for substantive reasonableness.

We first consider whether the district court committed procedural error, such as an improper Guidelines calculation or a sentence based on clearly erroneous facts, "review[ing] the district court’s factual findings for clear error and its application of the guidelines de novo." United States v. Hairy Chin, 850 F.3d 398, 402 (8th Cir. 2017) (per curiam) (quoting United States v. Barker, 556 F.3d 682, 689 (8th Cir. 2009) ). If we find no error, we review the sentence for substantive reasonableness.