John Kungu owned a successful business, Advanced Nursing Care, in Townsend, Delaware. He also owed the IRS nearly $1.2 million, and he decided to lie his way out of it.

In this episode of Final Notice, tax attorney Jason Carr breaks down how Kungu ran his scheme on two fronts: filing false personal and corporate returns that disguised hundreds of thousands of dollars in personal spending as business expenses, then submitting multiple false sworn statements to the IRS during collections claiming he couldn't pay.

The defining moment: Kungu offered to settle his entire tax debt for $35,000, said he'd need a loan to do it, and was holding more than $5.1 million in hidden accounts the whole time. He was sentenced to 18 months in federal prison, three years of supervised release, a $75,000 fine, and full restitution of $1,186,573.62.

Jason explains the legitimate tools Kungu ignored: the Offer in Compromise, installment agreements, currently-not-collectible status, penalty abatement, and real tax planning, and why every one of them starts with honest, fully disclosed financials.

This episode is for business owners, taxpayers facing IRS collections, bookkeepers, enrolled agents, CPAs, and tax preparers who want to understand exactly where an unpaid tax bill turns into a criminal case.

Key Takeaways

• The IRS will settle a tax debt for less than you owe, but only through an Offer in Compromise built on fully disclosed, honest financials.
• Lying on a sworn collection statement is what converts a civil collections problem into a federal criminal case.
• Running personal spending through your business as "expenses" is not a deduction. It is evidence.
• Hiding records from your own bookkeeper or tax preparer is the moment to call a tax attorney, not to dig deeper.
• What you tell a tax attorney is privileged. What you tell your bookkeeper is not.
• A large unpaid tax bill is a solvable problem. The solution is disclosure plus strategy, never a sworn lie.

Resources Mentioned

• DOJ / IRS-CI case source: https://www.justice.gov/usao-de/pr/delaware-business-owner-sentenced-18-months-federal-prison-multi-year-tax-evasion-scheme
• The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com

Congress created the Employee Retention Credit to help struggling businesses keep workers on payroll during the pandemic. Candies Goode-McCoy of Las Vegas treated it like an ATM.

From approximately June 2022 through September 2023, Goode-McCoy conspired with others to file more than 1,200 tax returns for her own businesses and for others, claiming the Employee Retention Credit and the paid sick and family leave credit, and seeking refunds totaling more than $98 million. The IRS paid out roughly $33 million before the scheme was stopped. Goode-McCoy personally received over $1.3 million in fraudulent refunds and about $800,000 more from clients, spending the proceeds on luxury cars, vacations, and gambling.

She pleaded guilty to one count of conspiracy to defraud the government with respect to claims and was sentenced to 54 months in prison, three years of supervised release, and more than $26 million in restitution to the IRS.

Jason explains why refundable credits like the ERC draw intense IRS scrutiny, how high-volume claims create unmistakable data patterns, and what a business should do if it already claimed an ERC it can no longer defend, including the ERC Voluntary Disclosure Program, claim withdrawal, amended returns, audit defense, and penalty relief.

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

Key Takeaways:

• A refundable credit is the most heavily scrutinized money in the tax code. A refund that sounds too good to be true usually is.
• The ERC was a legitimate program with specific eligibility rules: a government-ordered shutdown or a significant decline in gross receipts in qualifying periods.
• High-volume claims with repeated credits create detectable patterns. The IRS shifted most of its exam staff to audit ERC claims.
• Lifestyle that doesn't match reported income is a classic red flag investigators follow every time.
• Tax preparers should build practices on eligibility analysis, documentation, and defensible positions, not refund size.
• If you already claimed a credit you can't support, voluntary correction through the ERC Voluntary Disclosure Program or claim withdrawal is far better than waiting for the IRS to find it.
• The goal is to keep the matter in the civil tax resolution lane, through amended returns, audit defense, and penalty relief, before it becomes a criminal case.

Resources Mentioned:

• DOJ sentencing release: Business Owner Sentenced to Over Four Years in Prison for $100M COVID-19 Tax Credit Scheme
• DOJ District of Nevada release: Business Owner Sentenced to Over Four Years in Prison for $100M COVID-19 Tax Credit Scheme
• DOJ guilty plea release: Nevada Woman Pleads Guilty to Fraudulently Seeking Nearly $100M in COVID-19 Employment Tax Credits
• Related co-conspirator (IRS-CI): Nevada businesswoman pleads guilty to multimillion dollar scheme to fraudulently claim COVID-19 tax credits
• The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com

Dr. Pankaj Merchia controlled several sleep medicine companies and, on paper, looked like a Harvard-educated success story. Federal prosecutors said he was running a shell game.

From 2017 to 2019, Merchia billed insurers millions for sleep apnea machines former patients hadn't used in years, some of which had already been returned, and used the proceeds to buy a $2.1 million home. He billed an insurer over $390,000 for treating his own brother, and when told he couldn't, set up a new business under a nominee to keep the payments flowing.

The tax scheme used the same playbook. From 2009 to 2019, Merchia hid more than $6.5 million in income by claiming his businesses were owned by a co-conspirator, fabricating a 2008 "sale" backed by a $30 million appraisal, and claiming roughly $2 million in deductions a year for fifteen years. When the IRS audited, he produced a backdated promissory note the metadata exposed and claimed he earned just $1 a year, "much like the founders of Google and AOL."

After a ten-day trial in which he represented himself, a Boston jury deliberated about four hours and convicted him on all counts. Jason explains where legitimate succession planning, Section 197 amortization, entity structuring, and the IRS Voluntary Disclosure Practice could have solved Merchia's real problems, and why lying during an audit, not the audit itself, is what turns an IRS case into a DOJ case.

This episode is for physicians, business owners, CPAs, enrolled agents, and tax professionals who want to understand exactly where aggressive planning crosses into criminal tax fraud.

Key Takeaways:

• You cannot just put a "stand-in" or nominee owner on a business to avoid taxes while keeping total control. The IRS focuses on who actually signs the checks, runs the show, and spends the money (like paying personal credit cards and student loans directly from business accounts).
• A messy or aggressive audit is usually a civil issue settled with back taxes, penalties, and interest. What turns an audit into a federal criminal indictment is lying, inventing stories (like the "Google founder" defense), and feeding fabricated documents to investigators.
• Modern tax fraud is easily exposed by digital fingerprints. Backdating a promissory note or a sales agreement to make a transaction look old will fail because file metadata reveals exactly when the document was actually created.
• If you are exposed during an audit, the goal is containment, not doubling down on the lie. Utilizing the IRS Voluntary Disclosure Practice or filing amended returns can keep a case civil. Fabricating new documents completely destroys that option.
• Strategies like asset protection, income shifting, and Section 197 amortization deductions are perfectly legal. However, they require real ownership transfers, actual transactions, and verifiable records—not manufactured forms with zero substance.
• Self-representation in a federal fraud trial rarely ends well. Taxpayers facing serious audits need to bring in defense counsel early to protect themselves with attorney-client privilege and let an objective expert make the cold strategic calls.

Resources Mentioned:

• IRS-CI press release: Former Brookline doctor convicted of health care fraud and tax fraud
• DOJ press release: Doctor Convicted at Trial for Defrauding IRS and Health Care Insurers
• DOJ (District of Massachusetts): Former Brookline Doctor Convicted of Health Care Fraud and Tax Fraud
• The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com

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.

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.

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.

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.

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