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Final Notice

Final Notice

De : 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
Épisodes
  • Location, Location, Liquidation

    Location, Location, Liquidation
    Oct 30 2026

    Rishi Kapoor was CEO of Location Ventures, a Miami developer that raised about $89 million for projects that mostly were never built. Court records describe a yacht, a 2.8-carat diamond ring, and a $5.9 million Cocoplum home bought with misused investor funds.

    On the tax side, Location Ventures withheld about $1.3 million in payroll taxes and never paid them over, while Kapoor paid himself more than $2 million. His finance staff raised the issue in writing in 2019 and 2021. He admitted that false QuickBooks entries showed the taxes as paid and that investors received financial statements saying the same.

    He pleaded guilty to money laundering and a payroll tax conspiracy and received 136 months. Restitution remains open. I explain trust fund taxes, Slodov v. United States, the Trust Fund Recovery Penalty, and what a business owner should do the day payroll deposits fall behind.

    Key Takeaways

    • Withheld payroll taxes are held in trust for the United States. They are not working capital.
    • Falling behind on deposits is civil. False books and false statements about the taxes create criminal exposure.
    • Internal emails, prior IRS notices, and distributions to owners are how willfulness gets proven.
    • Make current deposits first, designate voluntary payments to the trust fund portion, and stop owner distributions.
    • Bring in a tax attorney before internal discussions about what to pay and what to defer, so those communications can be privileged.

    Resources and Legal References

    • DOJ sentencing announcement: https://www.justice.gov/usao-sdfl/pr/miami-real-estate-developer-sentenced-89-million-investor-fraud-and-tax-scheme
    • IRS-CI sentencing announcement: https://www.irs.gov/compliance/criminal-investigation/miami-real-estate-developer-sentenced-for-89-million-investor-fraud-and-tax-scheme
    • DOJ indictment announcement: https://www.justice.gov/usao-sdfl/pr/miami-developer-charged-85-million-fraud-scheme-used-fund-luxury-yacht-and-lifestyle
    • United States v. Kapoor, No. 26-cr-20073 (S.D. Fla.)
    • SEC v. Kapoor, No. 1:23-cv-24903 (S.D. Fla.): https://www.sec.gov/enforcement-litigation/litigation-releases/lr-25921
    • Investigative reporting on the indictment: https://www.miaminewtimes.com/news/a-yacht-a-rolex-and-a-single-digit-inside-rishi-kapoors-alleged-fraud-40559116
    • 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.
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    11 min
  • The $32 Million Address Change

    The $32 Million Address Change
    Oct 16 2026
    Company Number One wanted an overpayment applied to a later tax year. The filed IRS-CI affidavit says it returned a paper refund check with that request. Instead of applying the credit as requested, the IRS issued another check after processing false changes to the company’s business-account information. That check, for $32,495,888.58, reached Christopher Dowtin. A second company’s refund check for $26,156.50 also reached him.Dowtin brought both checks to a Morgan Stanley office in Ohio and attempted to place them into a trust-named brokerage account. He supplied documents purporting to support his authority over the money. Morgan Stanley contacted the Secret Service and IRS-CI, and agents seized the checks. Company representatives told investigators he was not authorized to act for them.After a bench trial, Dowtin was convicted of theft of government money and wire fraud. The court imposed 36 months in prison and 36 months of supervised release. The filed judgment lists no restitution; the government’s sentencing memorandum says intervention prevented actual financial loss. The district-court docket also records a notice of appeal.I explain what Form 8822-B does, why authority over a business’s IRS account matters, and what a business or tax professional should check when refund instructions and IRS correspondence stop matching.Key TakeawaysConfirm the address and responsible party recorded for each business IRS account.Reconcile refund checks and carryforward requests against account records, especially when a check arrives despite instructions to apply an overpayment forward.Verify an unfamiliar Form 2848 or purported fiduciary appointment with the business before treating it as authorized.Preserve notices, forms, account history, and communications if a change appears unauthorized.Treat missing expected IRS correspondence as a possible business identity-theft warning sign.Use the IRS’s business identity-theft reporting guidance when its stated criteria fit the facts.Resources and Legal ReferencesFiled IRS-CI complaint and agent affidavit: The investigated sequence, documents, company interviews, and checks. Allegations in the affidavit should be distinguished from the later verdict.Indictment: The charged theft and wire-fraud theory, including Forms 56, 2848, and 8822-B.United States v. Dowtin, No. 3:25-cr-00032, verdict: The bench-trial findings of guilt on the six counts that proceeded to trial.United States v. Dowtin, pretrial order, Feb. 6, 2026: The court’s treatment of proposed sovereign-citizen and mistake-of-law arguments, while preserving an opportunity to contest intent on a genuine factual basis.Government sentencing memorandum and judgment: The government’s account of prevented loss and the court’s actual sentence and monetary orders.IRS-CI sentencing account: Agency account of the disposition.Form 8822-B and instructions: Business address and responsible-party changes, signatory requirements, and representative authority.18 U.S.C. § 641: Theft or conversion of United States money or property.18 U.S.C. § 1343: Wire fraud.26 U.S.C. § 6109: Taxpayer identifying numbers. Dowtin’s convictions were under Title 18, not this IRC section.IRS business identity-theft guidance and business reporting guidance: Warning signs and reporting options.Related Steven Ware case: A separate corporate-refund impersonation comparison.The Law Office of Jason Carr, PLLC.DisclaimerThis 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 PolicyPlease 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.
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    13 min
  • The Godfather’s Other Ledger

    The Godfather’s Other Ledger
    Oct 9 2026
    Iris Rabaya Au formed shell companies and opened bank accounts at the direction of her then-boyfriend, Adam Iza, who called himself “The Godfather.” According to the government’s account of her plea, funds moving through those accounts paid approximately $1 million to sheriff’s deputies, supported nearly $10 million in recreational spending, and purchased approximately $16 million in cryptocurrency for Iza.Au admitted transferring more than $2.6 million from the company accounts into her personal accounts between 2020 and 2023 and willfully failing to report that income. Prosecutors also argued that she concealed entities and income from her tax preparer. She pleaded guilty to subscribing to a false return. On September 21, 2026, she was sentenced to 18 months in prison, ordered to pay $1,484,343 in restitution, and ordered to forfeit luxury assets.I follow the accounts behind the spending, distinguish money moved for someone else from money received personally, and explain why a preparer needs the complete financial picture before a taxpayer signs a return.Key TakeawaysReconcile transfers into personal accounts separately from payments made for an entity or another person.Give the return preparer a complete list of relevant entities and accounts.Support labels such as “loan” or “reimbursement” with records showing what happened.Compare the completed return against the underlying account reconciliation before signing.Coordinate tax corrections with the broader defense when funds may have an illegal source.The IRS Criminal Investigation Voluntary Disclosure Practice excludes taxpayers with illegal-source income.Resources and Legal ReferencesCentral District of California sentencing account: Au’s sentence, admitted transfers, forfeiture, and prosecutors’ preparer-concealment argument.Central District of California plea announcement: The government’s account of what Au agreed to admit.IRS-CI case account: Agency account of Au’s disposition and the financial structure.Related Saavedra sentencing account: A separate recipient’s false-return case within Iza’s operation.26 U.S.C. § 61: Gross income from whatever source derived.26 U.S.C. § 7206(1): Willfully subscribing to a materially false return under penalties of perjury. The official case accounts describe Au’s offense as false subscription; the filed charging document was unavailable for this draft.Rutkin v. United States, 343 U.S. 130 (1952): The Supreme Court held that extorted funds can be taxable income when the recipient controls and derives economic value from them. This is a comparison of tax principles, not a ruling about Au.IRS Criminal Investigation Voluntary Disclosure Practice: Current eligibility guidance, including its illegal-source-income exclusion.The Law Office of Jason Carr, PLLC.DisclaimerThis 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 PolicyPlease 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.
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    14 min
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