What is the test for determining whether a defendant's livelihood is a criminal livelihood?
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The following excerpt is from U.S. v. Davis, 961 F.2d 217 (9th Cir. 1992):
We review for clear error the district court's determination of criminal livelihood. United States v. Munster-Ramirez, 888 F.2d 1267, 1269 (9th Cir.1989), cert. denied, 495 U.S. 920 (1990).
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