Final Notice

Jason Carr, Esq.

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.

  1. 1d ago

    The Queen’s Refund

    Queen Naja, also known as Renata Winifred Ince and Naja Talibah Zahir, was sentenced to 165 months in prison for conspiracy to commit mail fraud after court records and trial evidence showed a scheme to use a legal trust, false tax documents, and a fraudulent payment to obtain a refund from the IRS. The IRS issued a Treasury check for $1,010,561.26, and the court later found additional false returns and fraudulent payments tied to refunds issued to Naja’s mother. The court also determined that additional attempted fraudulent payments would have caused another $428,732,324.56 in losses if successful. Jason explains why trusts are legitimate planning tools, why fake payment documents are criminal evidence, how IRS-CI proved the case through records and interviews, and what taxpayers should do before a questionable refund claim becomes a DOJ case. Key Takeaways A trust is legitimate only when the records, control, income, payments, and tax reporting match reality.A refund claim must be based on a real payment, credit, withholding, or overpayment.The line between civil tax risk and criminal exposure is often the fabricated document.IRS-CI cases are built through records: checks, vouchers, transcripts, returns, bank records, and statements.If IRS-CI is involved, privilege matters before the taxpayer tries to explain the facts.Large refund claims should be reviewed before filing, especially when trusts, payroll tax vouchers, or credits are involved.Resources Mentioned DOJ case source: https://www.justice.gov/usao-mdal/pr/pennsylvania-woman-sentenced-nearly-14-years-prison-role-2-million-fraud-schemeIRS-CI conviction source: https://www.irs.gov/compliance/criminal-investigation/pennsylvania-woman-convicted-in-million-dollar-government-fraud-schemeCourt record, recommendation on motion to suppress: https://ecf.almd.uscourts.gov/cgi-bin/show_public_doc?2024cr0437-8418 U.S.C. § 1341, mail fraud18 U.S.C. § 1349, attempt and conspiracy26 U.S.C. § 7206, fraud and false statementsBeckwith v. United States, 425 U.S. 341 (1976): https://www.law.cornell.edu/supremecourt/text/425/341Cheek v. United States, 498 U.S. 192 (1991): https://www.law.cornell.edu/supremecourt/text/498/192The Law Office of Jason Carr, PLLC: https://carrtaxlaw.comDisclaimer  This video is for informational and educational purposes only and does not constitute legal or tax advice. Viewing this video does not create an attorney-client relationship between you and The Law Office of Jason Carr, PLLC. The discussion is based on publicly available information and is not a complete analysis of any person’s legal rights, defenses, tax obligations, or case facts. Any commentary about what a taxpayer, business owner, or advisor “should have done” is general educational discussion only and may not apply to your situation. If you have a specific legal or tax question, consult a qualified attorney or tax professional licensed in your jurisdiction. Comment Policy Please do not post confidential, sensitive, or personally identifiable tax information in the comments. We do not provide individualized legal or tax advice in the comments or social media replies.

    The Queen’s Refund
  2. Jul 24

    The Twin Shell Game

    Dennis March and Greg March, twin brothers from Berlin, Maryland, each pleaded guilty to tax evasion for concealing income and failing to pay business and individual taxes. According to their guilty pleas, the brothers owned and controlled business entities and ventures including Elite Marketing Group LLC, Elite MG LLC, and Principal Law Group. The government said they concealed income by arranging payments to a shell entity they controlled, treating those payments as business expenses or costs when they were effectively distributions of income to themselves. Jason explains how related-party payments can cross the line from planning to concealment, why business expenses need real substance, how IRS-CI follows entity and bank records, and what business owners should do before missing returns and disguised distributions become criminal tax evidence. KeyTakeaways A shell entity does not make owner income disappear.Related-party payments need real services, real contracts, reasonable pricing, and clean tax reporting.A business expense must be ordinary and necessary, and the label does not override the economic reality.Large cash withdrawals, missing returns, and real estate purchases can help prosecutors tell the money-trail story.If prior filings are wrong, the cleanup should start before IRS-CI or the DOJ controls the timeline.Privilege matters when the facts involve concealed income, shell entities, missing returns, or potential willfulness. Resources Mentioned DOJ case source: https://www.justice.gov/usao-md/pr/maryland-brothers-plead-guilty-tax-evasion IRS Publication 334, business expenses: https://www.irs.gov/publications/p334 IRS online payment agreements: https://www.irs.gov/paymentplans The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com Case Source 26 U.S.C. § 7201: Attempt to evade or defeat tax. The statute provides felony penalties for any person who willfully attempts in any manner to evade or defeat tax or payment of tax.IRS Criminal Investigation Manual, IRM 9.1.3: Explains § 7201, including the requirement of an affirmative act and examples of conduct that may show an attempt to evade or defeat tax.Spiesv.UnitedStates, 317 U.S. 492 (1943): The Supreme Court distinguished passive failure to file or pay from felony evasion and identified examples of conduct that may show an attempt to evade or defeat tax.Cheekv.UnitedStates, 498 U.S. 192 (1991): The Supreme Court described willfulness in criminal tax cases as a voluntary, intentional violation of a known legal duty.IRS Publication 334, business expenses: The IRS explains that a deductible business expense must be ordinary and necessary, with “ordinary” meaning common and accepted in the business field and “necessary” meaning helpful and appropriate.Disclaimer  This video is for informational and educational purposes only and does not constitute legal or tax advice. Viewing this video does not create an attorney-client relationship between you and The Law Office of Jason Carr, PLLC. The discussion is based on publicly available information and is not a complete analysis of any person’s legal rights, defenses, tax obligations, or case facts. Any commentary about what a taxpayer, business owner, or advisor “should have done” is general educational discussion only and may not apply to your situation. If you have a specific legal or tax question, consult a qualified attorney or tax professional licensed in your jurisdiction. Comment Policy Please do not post confidential, sensitive, or personally identifiable tax information in the comments. We do not provide individualized legal or tax advice in the comments or social media replies.

    The Twin Shell Game
  3. Jul 17

    Slow Jamz, Faster Levies

    Carl Mitchell of Crete, Illinois, known professionally as Twista, pleaded guilty on June 24, 2026, to five counts tied to willfully failing to pay income tax for 2019 through 2023.  Court records and statements made in court indicate Mitchell earned income from performances, album sales, streaming, and royalties, and that both the IRS and Mitchell’s accountants repeatedly informed him of his tax debts and obligation to pay. Rather than paying the taxes owed, the government said Mitchell entered into third-party royalty advance agreements knowing the IRS could not levy those funds and made large lifestyle purchases, including at least four luxury vehicles. Jason explains the line between civil tax debt and criminal exposure, how IRS-CI proves willful failure to pay, why accountant and IRS warnings matter, and what taxpayers with irregular income should do before the IRS problem becomes a DOJ problem. Key Takeaways Tax debt is often a civil collection problem. Warnings, luxury spending, and collection avoidance can change the case. The IRS can follow creative income streams, including performances, streaming, royalties, licensing, and advances.Accountant warnings can become powerful willfulness evidence.Royalty advances and other financing tools can be legitimate, but the purpose matters when IRS collection is active. Taxpayers with irregular income should set aside tax reserves and make estimated payments.If the facts include possible intent evidence, privilege should be structured before casual explanations are given. Resources Mentioned IRS-CI case source: https://www.irs.gov/compliance/criminal-investigation/recording-artist-twista-pleads-guilty-to-tax-crimesThe Law Office of Jason Carr, PLLC: https://carrtaxlaw.comDisclaimer  This video is for informational and educational purposes only and does not constitute legal or tax advice. Viewing this video does not create an attorney-client relationship between you and The Law Office of Jason Carr, PLLC. The discussion is based on publicly available information and is not a complete analysis of any person’s legal rights, defenses, tax obligations, or case facts. Any commentary about what a taxpayer, business owner, or advisor “should have done” is general educational discussion only and may not apply to your situation. If you have a specific legal or tax question, consult a qualified attorney or tax professional licensed in your jurisdiction. Comment Policy Please do not post confidential, sensitive, or personally identifiable tax information in the comments. We do not provide individualized legal or tax advice in the comments or social media replies.

    Slow Jamz, Faster Levies
  4. Jul 10

    Own Nothing, Control Everything

    A federal jury convicted Marcia Predmore, Roderick Prescott, Suzanne Thompson, and Weldon Wulstein for their roles in an abusive layered trust tax shelter that DOJ says helped business owners evade federal income tax on up to 98 percent of business profits.  The shelter used a business trust, family trust, charitable trust, and private family foundation, and was marketed with the phrase “own nothing, control everything.”  Jason explains how abusive trust structures cross the line, why warnings from attorneys, CPAs, financial professionals, and IRS guidance matter in criminal tax cases, and what legitimate business owners should do instead when they need tax planning, asset protection, estate planning, or charitable giving advice.  Key Takeaways  A trust is not a device for making taxable income disappear. Asset protection and estate planning are legitimate goals, but they need real legal substance and clean tax reporting. Personal expenses do not become deductible because they move through a trust. Charitable deductions require real charitable transfers, substantiation, and loss of personal control. Tax professionals should be cautious when a promoter asks them to prepare returns based on a packaged tax shelter. If the plan depends on a slogan like “own nothing, control everything,” get independent tax counsel before signing or paying. Resources Mentioned  DOJ case source: https://www.justice.gov/opa/pr/four-abusive-tax-shelter-promoters-found-guilty-40m-nationwide-tax-evasion-scheme The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com Disclaimer  This video is for informational and educational purposes only and does not constitute legal or tax advice. Viewing this video does not create an attorney-client relationship between you and The Law Office of Jason Carr, PLLC. The discussion is based on publicly available information and is not a complete analysis of any person’s legal rights, defenses, tax obligations, or case facts. Any commentary about what a taxpayer, business owner, or advisor “should have done” is general educational discussion only and may not apply to your situation. If you have a specific legal or tax question, consult a qualified attorney or tax professional licensed in your jurisdiction. Comment Policy Please do not post confidential, sensitive, or personally identifiable tax information in the comments. We do not provide individualized legal or tax advice in the comments or social media replies.

    Own Nothing, Control Everything
  5. Jul 3

    Under the Table, Over the Limit

    Vinh Q. Ho and Thanh Lan Do owned and managed a nationwide nail salon business operating under Anthony Vince Nail Salons, Prive Nail Spas, and Zen Nail & Spas. Prosecutors said the business paid a significant portion of nail technician compensation in cash, omitted that cash from year-end tax forms, trained salon managers to operate the under-the-table payroll, prepared false Forms 1099, and instructed employees to keep the true payroll hidden.  In this episode, Jason explains how cash payroll becomes criminal tax exposure, why false information reporting is dangerous, how worker classification should be analyzed, and what a business owner should do before a payroll tax issue becomes an IRS-CI investigation.  Key Takeaways Cash compensation still has to be reported.A Form 1099 does not make a worker an independent contractor if the actual relationship points the other way.False payroll forms can become evidence of concealment.Training managers to hide payroll turns a tax problem into a system problem.Payroll cleanup should start before IRS-CI is involved.Privilege matters when a business owner is trying to understand serious tax exposure.Case Source  DOJ: Owners of Nationwide Nail Salon Business Plead Guilty to Tax Crimes IRS-CI: Owners of nationwide nail salon business plead guilty to tax crimes Disclaimer  This video is for informational and educational purposes only and does not constitute legal or tax advice. Viewing this video does not create an attorney-client relationship between you and The Law Office of Jason Carr, PLLC. The discussion is based on publicly available information and is not a complete analysis of any person’s legal rights, defenses, tax obligations, or case facts. Any commentary about what a taxpayer, business owner, or advisor “should have done” is general educational discussion only and may not apply to your situation. If you have a specific legal or tax question, consult a qualified attorney or tax professional licensed in your jurisdiction. Comment Policy Please do not post confidential, sensitive, or personally identifiable tax information in the comments. We do not provide individualized legal or tax advice in the comments or social media replies.

    Under the Table, Over the Limit
  6. Jun 26

    Trust Me, It Was Fraud

    A trust can be a legitimate estate planning tool. In this case, prosecutors said purported trusts became the vehicle for a multimillion-dollar tax refund fraud scheme. Brandon Hunt, his father David Hunt, his twin brother Baylon Hunt, and his half-brother Corey Burt were convicted at trial for their roles in a scheme to file false tax returns in the names of trusts they controlled. Prosecutors said the defendants sought more than $8.5 million in refunds, received over $1.7 million from the IRS, and used the proceeds to buy luxury goods, furniture, cryptocurrency, a Cadillac Escalade, and a house in Mississippi. Jason explains why trusts do not create refunds by magic, how IRS warning letters can become a major aggravating fact, and what taxpayers should do when a trust, refund claim, or prior filing starts to look indefensible. Key Takeaways A trust is a legal structure, not a refund generator.A refund claim must be supported by real income, real payments, real deductions, and real documentation.IRS warning letters should be treated as an escalation point, not background noise.Continuing after a warning letter can turn a bad filing position into a much more serious case.Tax professionals should slow down when a client presents a trust strategy that produces an unusually large refund.If prior returns are wrong, the correct path depends on willfulness, timing, and whether the IRS has already identified the issue.Voluntary disclosure may help address willful noncompliance only if the disclosure is truthful, timely, and complete, and made before key IRS enforcement triggers occur.Case Source DOJ press release: Final Defendant Sentenced to Prison in Multimillion Dollar Tax Refund Fraud SchemeIRS-CI press release: Final defendant sentenced to prison in multimillion dollar tax refund fraud schemeResources Mentioned DOJ case source: https://www.justice.gov/opa/pr/final-defendant-sentenced-prison-multimillion-dollar-tax-refund-fraud-schemeIRS-CI case source: https://www.irs.gov/compliance/criminal-investigation/final-defendant-sentenced-to-prison-in-multimillion-dollar-tax-refund-fraud-schemeIRS Form 1041: https://www.irs.gov/forms-pubs/about-form-1041IRS Voluntary Disclosure Practice: https://www.irs.gov/compliance/criminal-investigation/irs-criminal-investigation-voluntary-disclosure-practiceLearn more: https://carrtaxlaw.comDisclaimer  This video is for informational and educational purposes only and does not constitute legal or tax advice. Viewing this video does not create an attorney-client relationship between you and The Law Office of Jason Carr, PLLC. The discussion is based on publicly available information and is not a complete analysis of any person’s legal rights, defenses, tax obligations, or case facts. Any commentary about what a taxpayer, business owner, or advisor “should have done” is general educational discussion only and may not apply to your situation. If you have a specific legal or tax question, consult a qualified attorney or tax professional licensed in your jurisdiction. Comment Policy Please do not post confidential, sensitive, or personally identifiable tax information in the comments. We do not provide individualized legal or tax advice in the comments or social media replies.

    Trust Me, It Was Fraud
  7. Jun 16

    Credit Where Credit Isn't Due

    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 Disclaimer  This video is for informational and educational purposes only and does not constitute legal or tax advice. Viewing this video does not create an attorney-client relationship between you and The Law Office of Jason Carr, PLLC. The discussion is based on publicly available information and is not a complete analysis of any person’s legal rights, defenses, tax obligations, or case facts. Any commentary about what a taxpayer, business owner, or advisor “should have done” is general educational discussion only and may not apply to your situation. If you have a specific legal or tax question, consult a qualified attorney or tax professional licensed in your jurisdiction. Comment Policy Please do not post confidential, sensitive, or personally identifiable tax information in the comments. We do not provide individualized legal or tax advice in the comments or social media replies.

    Credit Where Credit Isn't Due
  8. Jun 16

    The $35,000 Lie

    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 Disclaimer  This video is for informational and educational purposes only and does not constitute legal or tax advice. Viewing this video does not create an attorney-client relationship between you and The Law Office of Jason Carr, PLLC. The discussion is based on publicly available information and is not a complete analysis of any person’s legal rights, defenses, tax obligations, or case facts. Any commentary about what a taxpayer, business owner, or advisor “should have done” is general educational discussion only and may not apply to your situation. If you have a specific legal or tax question, consult a qualified attorney or tax professional licensed in your jurisdiction. Comment Policy Please do not post confidential, sensitive, or personally identifiable tax information in the comments. We do not provide individualized legal or tax advice in the comments or social media replies.

    The $35,000 Lie

About

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.