the offense for altering documents and the guidelines prohibit adding criminal history points for conduct that is “not part of the instant offense.” See U.S.S.G. § 4A1.2(a)(l). Conduct “part of the instant offense” means relevant conduct that, under § 1B1.3, could be used to determine the defendant’s base offense level. See § 4A1.2(a)(l), cmt. n.l. Bishop’s argument has superficial appeal because the crimes were temporally close, but that has nothing to do with their relationship under § 4A1.2(a)(l). Bishop’s drug and money laundering offenses played no part in the commission of this altered-document conviction, and Bishop had been convicted of the former offenses well before engaging in the latter criminal conduct. See United States v. Browning, 252 F.3d 1153, 1158-59 (10th Cir.2001) (<HOLDING>) (citation and internal quotation marks
holding that the greater offense is  by definition the same for purposes of double jeopardy as any lesser offense included in it holding that challenge to evidentiary sufficiency was waived where defendant stipulated before the trial court to all elements of the offense holding that two offenses are separate for the purposes of  4a12a1 where all the elements of the first offense occurred before any activity forming the basis of the second offense holding that the victim and witness protection act limits the amount of restitution to the loss caused by the specific conduct forming the basis of the offense of conviction holding that in the conviction and sentencing for criminal offenses committed in the course of one criminal episode it is the intent of the legislature that there be a separate conviction and sentence for each criminal offense unless one of the offenses is a degree of the other a necessarily included lesser offense subsumed in the other or both offenses are identical