The Golf Course Gambit
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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