The following excerpt is from U.S. v. Parker, 990 F.2d 1264 (9th Cir. 1993):
Possession of a firearm during the commission of an offense by itself renders enhancement appropriate. United States v. Restrepo, 884 F.2d at 1296. But see United States v. Kelso, 942 F.2d 680 (9th Cir.1991). This court has enlarged the geographical scope of "possession." See, e.g. United States v. Heldberg, 907 F.2d 91, 93-94 (9th Cir.1990) (revolver in locked briefcase in car trunk supported enhancement because near to drugs found on driver).
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