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Final Notice

Final Notice

著者: Jason Carr Esq.
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Final Notice s a weekly podcast where tax attorney Jason Carr breaks down real tax fraud prosecutions and reveals what should have been done to avoid them. New episodes every Friday at carrtaxlaw.com.

© 2026 The Law Office of Jason Carr, PLLC
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  • Trust Fund, Broken Trust
    2026/06/15

    Harry Lamar Curtis III owned Information Advisory Group LLC, a cybersecurity and IT company based in Houston. He was also a former certified public accountant.

    According to the Department of Justice, Curtis was required to withhold and pay over employment taxes from employee paychecks, including federal income taxes, FICA taxes, and employer matching amounts. As part of his plea, Curtis admitted that he failed to file business tax returns for Information Advisory Group since 2016 and improperly withheld $1,647,142 that was due to the IRS. He also admitted he had not filed individual tax returns for himself since 2008.

    In this episode of Final Notice, Jason explains why payroll tax cases are different, why withheld taxes are not business operating cash, and what business owners should do if payroll tax problems begin to stack up.

    The episode covers payroll tax compliance, unfiled business returns, unfiled personal returns, trust fund exposure, IRS-CI referral risk, civil tax resolution options, and why attorney-client privilege matters when payroll tax facts become serious.

    Key Takeaways:

    • Payroll taxes are not business cash. When a business withholds taxes from employee wages, that money must be paid over to the government.
    • File the returns even if the business cannot pay in full. Unfiled returns make collection and resolution harder.
    • Payroll tax debt needs immediate triage. The business must become current on new deposits before old debt can be addressed effectively.
    • Trust fund payroll taxes can create personal exposure for responsible persons, including owners and decision-makers.
    • A civil resolution plan may include compliance cleanup, installment agreements, penalty abatement, payroll controls, restructuring, or winding down the business.
    • Privilege matters when payroll tax issues involve years of non-filing, withheld taxes, missing deposits, or potential false statements.

    Suggested Timestamps:

    00:00: Cold open, a former CPA, $1.6 million, and missing returns

    00:30: Branded intro, Final Notice: Real Tax Cases. Exposed.

    00:45: Who Harry Lamar Curtis III was

    01:30: Information Advisory Group LLC and the Houston connection

    02:15: What payroll taxes are and why they are different

    03:15: Business returns missing since 2016

    04:00: Individual returns missing since 2008

    04:45: How payroll tax cases get built from records

    06:00: Why payroll tax debt often starts as cash flow stress

    07:00: What Curtis should have done instead

    08:15: File returns, stop the bleeding, and get current

    09:15: Trust fund exposure and responsible persons

    10:15: Civil resolution options for payroll tax debt

    11:15: Why privilege matters before the facts get worse

    12:00: Final lesson, payroll taxes are not a float

    12:30: Close and call to action

    Resources Mentioned:

    • DOJ case source: https://www.justice.gov/usao-sdtx/pr/houston-business-owner-sent-prison-failing-pay-over-16-million-taxes
    • IRS-CI plea source: https://www.irs.gov/compliance/criminal-investigation/houston-business-owner-admits-to-failing-to-pay-over-1-point-6-million-in-taxes
    • The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com
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    9 分
  • Beyond a Reasonable Blockchain
    2026/06/15

    David Gebhardt was a Tennessee-licensed attorney from Brentwood. According to DOJ, he bought cryptocurrency, used decentralized exchanges and nominees to conceal income, and failed to report millions of dollars in income from cryptocurrency sales and his consulting business.

    From March 2018 through December 2022, DOJ says Gebhardt withdrew approximately $6.6 million from cryptocurrency sales. Despite being warned by his accountants to report all cryptocurrency income, he failed to do so, and on his 2020 through 2022 returns he indicated that he did not engage in virtual currency transactions when he had.

    Jason explains why the digital asset question on Form 1040 matters, how crypto records can become evidence, and why “I didn’t receive a tax form” is not a defense to failing to report income. The episode also covers the better path: transaction reconstruction, Form 8949, Schedule D, amended returns, payment planning, penalty strategy, and keeping serious tax problems in the civil IRS lane whenever possible.

    This episode is for taxpayers, business owners, crypto investors, attorneys, accountants, enrolled agents, CPAs, and anyone who has digital asset activity that has not been properly reported.

    Key Takeaways:

    • The IRS digital asset question must be answered accurately. Taxpayers must answer “Yes” or “No” to whether they received, sold, exchanged, or otherwise disposed of a digital asset during the year.
    • Digital asset income must be reported on the federal tax return.
    • Sales, exchanges, and other dispositions of digital assets held as capital assets generally belong on Form 8949, with totals summarized on Schedule D.
    • Ordinary income from digital assets, including forks, staking, and mining, generally belongs on Schedule 1.
    • Taxpayers must report digital asset income, gains, or losses whether they receive Form 1099-DA or not.
    • When accountants warn a taxpayer to report income, that warning can become a major fact if the taxpayer later files false returns.
    • A prior filing problem is usually easier to fix before IRS-CI is involved.

    Suggested Timestamps

    00:00: Cold open, $6.6 million in crypto sales and the “No” checkbox

    00:30: Branded intro, Final Notice: Real Tax Cases. Exposed.

    00:45: Who David Gebhardt is and why the case matters

    02:00: Crypto sales, decentralized exchanges, and nominees

    03:15: The accountant warning

    04:00: The digital asset question on the tax return

    05:30: Why the checkbox can become evidence

    06:30: Consulting income and pattern evidence

    07:30: Guilty plea, tax loss, sentencing exposure

    08:30: What should have happened instead

    09:30: Form 8949, Schedule D, Schedule 1, and amended returns

    10:30: Why privilege matters when facts are serious

    11:30: Final lesson, crypto is not a tax-free zone

    Resources Mentioned:

    • DOJ case source: https://www.justice.gov/usao-mdtn/pr/brentwood-attorney-pleads-guilty-tax-fraud
    • IRS digital assets page: https://www.irs.gov/filing/digital-assets
    • IRS digital asset reporting reminder: https://www.irs.gov/newsroom/reminders-for-taxpayers-about-digital-assets
    • The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com
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    8 分
  • Schedule C for Make-Believe
    2026/06/15

    Kerwin Aldric Jordan was a California tax preparer who operated The Jordan Corporation and Jordan and Jordan A Financial Conquest. Prosecutors said he held himself out as a tax attorney and certified public accountant, even though he was neither.

    In this episode of Final Notice, Jason Carr breaks down how Jordan used non-existent businesses and fake business losses to reduce clients’ taxable income. The episode also covers the COVID relief loan side of the case, where prosecutors said Jordan received PPP and EIDL funds after falsely reporting that companies had employees when they had none.

    Jason explains why fake Schedule C losses create obvious audit and criminal exposure, how high-volume preparer patterns can create a data trail, and what taxpayers should do if they discover a preparer filed returns claiming businesses, losses, credits, or expenses that were not real.

    This episode is for taxpayers, small business owners, tax preparers, enrolled agents, CPAs, bookkeepers, and anyone who wants to understand where aggressive tax preparation crosses into criminal tax fraud.

    Key Takeaways:

    • A real business loss needs a real business.
    • A Schedule C is not a place to park fictional expenses.
    • Large preparer fees tied to large refunds should raise questions.
    • Taxpayers should understand the return before signing it.
    • Preparers should document intake, verify business activity, and refuse unsupported deductions.
    • Fake credentials are a serious warning sign. If someone claims to be a tax attorney or CPA, verify it.
    • If prior returns include false businesses, false deductions, or fake credits, review the exposure before contacting the IRS.
    • When facts involve false returns, COVID relief applications, or fake records, privilege matters.

    Suggested Timestamps:

    00:00: Cold open, 1,370 returns and $73 million in claimed losses

    00:30: Branded intro, Final Notice: Real Tax Cases. Exposed.

    00:45: Who Kerwin Aldric Jordan was

    01:45: The Jordan Corporation and “A Financial Conquest”

    02:30: Fake businesses and fake business losses

    03:45: The $2 million couple and the nearly $28,000 prep fee

    05:00: More than 1,370 returns and $25 million in alleged tax loss

    06:15: PPP loans, EIDL loans, and fake employees

    07:30: How preparer fraud patterns get detected

    09:00: What taxpayers should do before signing a return

    10:15: What tax professionals should learn from the case

    11:30: Cleanup options for bad returns

    12:30: Final lesson, if the business does not exist, the deduction does not either

    Resources Mentioned

    • DOJ case source: https://www.justice.gov/opa/pr/california-tax-preparer-pleads-guilty-filing-false-returns-and-fraudulently-obtaining-covid
    • The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com
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    9 分
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