of limitations did not expire because Count V implicitly alleged that Dunne caused PanWorld to submit the false statements to the SEC is unavailing. B. Continuing Offense Doctrine The government also argues that the making of a false statement under 18 U.S.C. § 1001 should be treated as a continuing offense and the statute of limitations should not begin running before the statement has the potential to deceive and the government could reasonably discover the crime. Therefore, the government argues the statute of limitations did not begin to run until the audit report certified by Dunne was submitted to the SEC. Because the government did not raise this argument in the district court, it is reviewed on appeal for plain error. Cf. United States v. Ivy, 83 F.3d 1266, 1297 (10th Cir.1996) (<HOLDING>). “ ‘Continuing offense’ is a term of art that
holding district courts adoption of the presentence report constitutes sufficient findings holding that if the government fails to object to the presentence report the district courts reliance on the report is reviewed for plain error holding that the district court committed plain error in relying solely on the factual description in the presentence report holding defendants failure to object to the drug quantity assessment in the presentence report at sentencing was a waiver of the issue on appeal holding that the information contained in a presentence report is reliable because it is based upon the presentence officers research of the records contact with relevant agencies and the gathering of information which is required to be included in a presentence report