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

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

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

Rene Mauricio Escobar and Juana Nelida Escobar operated Escobar Plastering in Orlando, Florida. Federal prosecutors said they used the company to help construction subcontractors pay workers off the books, avoid payroll taxes, and avoid workers’ compensation insurance premiums.

According to the DOJ, the defendants caused certificates of insurance in Escobar Plastering’s name to be sent to construction contractors, representing that subcontractors’ workers were employed by and covered under Escobar Plastering. Prosecutors said the insurance policies were actually based on applications showing only a handful of employees and minimal payroll.

The government said thousands of payroll checks totaling approximately $148,760,824 were deposited into Escobar Plastering bank accounts. The defendants then withdrew cash to pay workers after keeping a 7% to 8% fee, while no one withheld or paid over payroll taxes to the IRS.

Rene Escobar was sentenced to four years and nine months in federal prison. Juana Escobar was sentenced to two years. The court ordered them to pay $37,174,388 in restitution to the IRS for unpaid payroll taxes.

Jason explains how construction payroll fraud unravels, why cash payroll leaves a paper trail, and what business owners should do instead: classify workers correctly, use real payroll systems, file Forms 941, make employment tax deposits, reconcile wage reporting, and get privilege-protected advice early when the facts show possible willfulness.

This episode is for business owners, contractors, subcontractors, payroll companies, bookkeepers, tax preparers, CPAs, enrolled agents, and anyone who wants to understand how payroll tax problems become IRS-CI cases.

Key Takeaways:

• Payroll is evidence. Checks, deposits, cash withdrawals, Forms 941, W-2s, insurance certificates, and bank records all tell a story.
• Off-the-books payroll can create tax, insurance, immigration, labor, and fraud exposure.
• Employers generally must withhold federal income tax, Social Security tax, and Medicare tax from employee wages and pay the employer share of Social Security and Medicare taxes.
• Employers use Form 941 to report federal income tax withheld from employees’ paychecks and both the employer and employee shares of Social Security and Medicare taxes.
• Using a payroll provider can help administratively, but IRS instructions warn that employers generally remain responsible for tax filings, deposits, and payments even when a third party performs payroll functions.
• If a payroll problem involves false documents, cash payments, sham subcontractor structures, or multi-year noncompliance, attorney-client privilege matters.
• The goal is to keep payroll tax problems in the civil IRS lane whenever possible through clean filings, corrected returns, current deposits, installment agreements, penalty analysis, and documented compliance cleanup.

Suggested Timestamps:

00:00: Cold open, $148 million in payroll and $37 million in unpaid payroll taxes

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

00:45: Who Rene and Juana Escobar were

01:30: Escobar Plastering and the construction payroll setup

02:45: Insurance certificates, minimal payroll, and hundreds of workers

04:00: How payroll checks became cash

05:15: Why the paper trail matters

06:15: IRS-CI, HSI, and workers’ compensation investigators

07:30: The sentencing and restitution

08:15: What the defendants should have done instead

09:15: Payroll compliance basics, Forms 941, deposits, and W-2s

10:15: Civil cleanup options before criminal exposure hardens

11:15: Why privilege matters in payroll tax cases

12:00: Final lesson, payroll is evidence

12:30: Close and call to action

Resources Mentioned:

• DOJ case source: https://www.justice.gov/usao-mdfl/pr/two-orlando-residents-sentenced-148-million-construction-payroll-scheme-defrauded-irs
• IRS Form 941 information: https://www.irs.gov/forms-pubs/about-form-941
• IRS employment tax deposit rules: https://www.irs.gov/taxtopics/tc757
• IRS Criminal Investigation Voluntary Disclosure Practice: https://www.irs.gov/compliance/criminal-investigation/irs-criminal-investigation-voluntary-disclosure-practice
• The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com

Michael Kirouac owned or controlled four companies: HK Manchester, HK Loudon, HK Hudson, and HK Pelham. Prosecutors said he applied for and obtained more than $1 million in Economic Injury Disaster Loans, certifying that the money would be used solely as working capital and not for personal expenses or business relocation.

But when Kirouac wanted to purchase Angus Lea Golf Course and could not obtain financing from banks or private lenders, prosecutors said he used approximately $600,000 of EIDL funds intended for HK Manchester and HK Loudon to help buy the course. He also obtained a $260,500 EIDL for HK Hudson after he had already agreed to sell that business, without disclosing the sale agreement to the SBA.

Kirouac pleaded guilty to wire fraud on October 3, 2025, and was sentenced on February 19, 2026, to 15 months in prison and one year of supervised release.

Jason explains why restricted government relief funds are not flexible deal money, how EIDL misuse can become a criminal case, and what business owners should do before moving loan proceeds into acquisitions, personal expenses, related entities, or new ventures.

Key Takeaways:

• Restricted funds must be used for restricted purposes.
• Loan certifications are evidence, not administrative clutter.
• A failed financing search does not justify using government relief money as acquisition capital.
• If a business owner has already misused restricted funds, the first move is to stop, preserve records, and get privileged legal review before creating more documents.
• The goal is to fix the issue while it can still be handled as a civil tax, loan, or administrative problem whenever possible.

Suggested Timestamps:

00:00: Cold open, COVID relief money and a golf course

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

00:45: Who Michael Kirouac was

01:45: The four HK companies

02:30: What EIDL funds were supposed to be used for

03:30: The golf course financing problem

04:30: The Angus Lea Golf Course purchase

05:45: Why EIDL misuse creates a paper trail

06:45: HK Hudson and the undisclosed sale issue

07:45: Guilty plea and sentencing

08:30: What he should have done instead

10:00: Legitimate financing alternatives

11:00: What to do if restricted funds were already misused

12:00: Final lesson, restricted funds are restricted for a reason

12:45: Close and call to action

Resources Mentioned:

• DOJ sentencing release: https://www.justice.gov/usao-nh/pr/pembroke-man-sentenced-misusing-cares-act-funds-purchase-angus-lea-golf-course
• IRS-CI sentencing release: https://www.irs.gov/compliance/criminal-investigation/pembroke-man-sentenced-for-misusing-cares-act-funds-to-purchase-the-angus-lea-golf-course
• The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com

Rafael Alvarez built a high-volume tax preparation business in the Bronx. Prosecutors say he also built one of the largest tax fraud schemes ever committed by a return preparer.

In this episode of Final Notice, Jason Carr, tax attorney, breaks down how Alvarez and ATAX New York allegedly prepared tens of thousands of false federal income tax returns using bogus itemized deductions, made-up capital losses, phony business expenses, and fraudulent tax credits.

Alvarez became known to customers as “the Magician” because of his supposed ability to make tax burdens disappear. But federal prosecutors said the “magic” caused $145 million in tax loss to the IRS and generated approximately $12 million in fraudulent proceeds for ATAX.

Jason explains how a preparer fraud case like this unravels, why inflated refunds create audit and criminal exposure, and what taxpayers should do if they discover that a preparer filed inaccurate or fraudulent returns on their behalf.

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

Key Takeaways:

• A large refund is not proof that a preparer did good work. It may be a red flag if the refund depends on deductions, credits, expenses, or losses the taxpayer cannot support.
• Taxpayers are responsible for the return they sign, even when a paid preparer completed it.
• Tax preparers should build their practices around documentation, review procedures, accurate intake, and defensible positions, not refund size.
• High-volume tax preparation businesses create detectable patterns when the same unsupported items appear across large numbers of returns.
• If a taxpayer discovers that prior returns were inaccurate, voluntary correction is usually better than waiting for the IRS to find the issue.
• If the facts are serious, privilege matters. A tax attorney can help evaluate the issue before the taxpayer creates unnecessary risk through careless communications.
• The goal is to keep the matter in the IRS civil tax resolution lane whenever possible, through amended returns, audit defense, penalty relief, and compliance cleanup.

Suggested Timestamps:

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

00:45: Who Rafael Alvarez was and how ATAX operated

02:00: The false deductions, capital losses, business expenses, and credits

03:15: Why customers called Alvarez “the Magician”

04:00: How the scheme unraveled

05:30: Employee intimidation, false statements, and obstruction concerns

06:45: Sentencing, restitution, forfeiture, and supervised release

07:45: What tax preparers should have done instead

09:15: What taxpayers should do if their preparer filed false returns

10:45: Why attorney-client privilege matters when facts get serious

11:45: Final lesson, if the result depends on magic, get a second opinion

12:30: Close and call to action

Resources Mentioned:

• IRS-CI case source: https://www.irs.gov/compliance/criminal-investigation/bronx-tax-preparer-sentenced-to-prison-for
  -filing-tens-of-thousands-of-false-tax-returns-causing-145-million-in-fraudulent-tax-loss
• DOJ sentencing release: https://www.justice.gov/usao-sdny/pr/bronx-tax-preparer-sentenced-prison-filing-tens-thousands
  -false-tax-returns-causing
• DOJ guilty plea release: https://www.justice.gov/usao-sdny/pr/bronx-tax-preparer-pleads-guilty-filing-tens-thousands-fals
  e-tax-returns-causing-145
• The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com