A non-parole period of 18 months on a four-year head sentence for sustained, sophisticated Commonwealth fraud involving $135,000 obtained through 33 fabricated tax returns over two and a half years, with no recovery and minimal mitigation, is within the range of reasonable sentencing discretion. Comparable cases are useful for demonstrating approximate ranges but do not invite point-by-point comparison, and appellate courts should not engage in fine-tuning of non-parole periods.
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