Final Notice

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.

Final Notice is a true crime podcast hosted by Jason Carr, Esq., with 18 episodes on record and a Required Pod Score of 80. PitchCentric scores this show on Booking Probability, Listen Score, and live audience signals refreshed every 24 hours.

Jason Carr, Esq. hosts Final Notice, a true crime show with 18 episodes published.

Our AI reads these to draft pitches. Use them as grounding for a pitch that cites a real guest and a specific topic.

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  Episode #18

  The Ghost Companies

  Aug 14, 202610 min

  Steven T. Loo had every advantage: eight commercial properties across Washington and California, a stack of LLCs, and a net worth prosecutors pegged at around $43 million. What he didn't have was any intention of paying his taxes. For years, Loo directed his property managers to send building profits into two bank accounts held by shell companies that had been dormant since 1999, spent the money on himself and his family, and never reported it. He didn't even tell his tax preparer the income existed. Viewed across two decades, his returns claimed he owed nothing and sometimes claimed a refund. A federal jury convicted Loo of six counts of tax evasion and six counts of filing false returns. In July 2026 he was sentenced to 20 months in prison, a $250,000 fine, and three years of supervised release, after prosecutors sought 51 months and called his motive simple greed. In this episode, Jason Carr explains the affirmative-act rule that separates a civil audit from a felony under IRC § 7201, why filing a false return under § 7206(1) is its own crime, and how IRS Criminal Investigation used property-management records, bank records, and the preparer's own testimony to close the "honest mistake" door. He also walks through the fork in the road every taxpayer faces when a criminal investigator shows up, and the voluntary-disclosure and compliance path that could have kept this an IRS matter instead of a DOJ case. Key Takeaways Owing tax is civil. Building a structure to hide income is what makes it criminal. Concealment is the line. Routing income through shell companies or inactive entities is a classic "affirmative act" of evasion under Spies v. United States . Hiding income from your own tax preparer destroys the "my accountant did it" defense and helps prove willfulness. IRS-CI builds these cases on paper: third-party property records, bank flows, and the gap between income earned and income reported. When a criminal investigator knocks, improvising an explanation creates new evidence. Get counsel and protect privilege. If prior years are wrong, voluntary disclosure and amended returns through counsel beat waiting to be caught, especially when you can afford to pay. Resources Mentioned DOJ / U.S. Attorney's Office, W.D. Wash., "Seattle real estate investor sentenced to 20 months in prison for $4.7 million tax evasion scheme" (July 17, 2026): https://www.justice.gov/usao-wdwa/pr/seattle-real-estate-investor-sentenced-20-months-prison-47-million-tax-evasion-scheme UnitedStatesv.Loo , No. 2:24-cr-00072 (W.D. Wash.) — indictment returned April 24, 2024.5 26 U.S.C. § 720 1 — Attempt to evade or defeat tax (felony evasion). 26 U.S.C. § 7206(1 ) — Fraud and false statements / filing a false return. Spiesv.UnitedStates , 317 U.S. 492 (1943) — felony evasion requires an affirmative act of concealment, not mere failure to file or pay: https://supreme.justia.com/cases/federal/us/317/492/ Cheekv.UnitedStates , 498 U.S. 192 (1991) — willfulness and the limits of a good-faith defense: https://supreme.justia.com/cases/federal/us/498/192/ 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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  Episode #17

  No Employees, No Credit

  Aug 7, 202612 min

  Regina Durkin, of New River, Arizona, pleaded guilty to one count of conspiracy to file false claims after court records indicated that she and others submitted false quarterly employment tax returns to the IRS. The claims sought refunds based on the Employee Retention Credit and the paid sick and family leave credit, pandemic-era credits designed to help qualifying employers. According to court records, the companies were not operating at the time, had no employees, and paid no wages. In total, Durkin and others submitted fourteen fraudulent claims requesting more than $7.7 million in tax refunds. Sentencing is scheduled for September 11, and the offense carries a maximum penalty of ten years in prison. Jason explains the line between an unsupported ERC claim and a criminal false-claims case, why payroll records matter, how IRS-CI follows employment tax filings, and what taxpayers and tax professionals should do before a questionable refund claim becomes an IRS-CI problem. Key Takeaways Payroll credits require payroll. If there are no employees and no wages, the claim fails at the foundation. A weak ERC claim may create a civil IRS problem. A fabricated payroll story can create criminal exposure. Forms 941 and payroll records are not administrative details. They are evidence. Tax professionals should verify source records before preparing or supporting ERC, paid leave, or other payroll credit claims. If an unsupported claim has already been filed, move quickly to assess withdrawal, amendment, repayment, penalty defense, and privilege-sensitive communications. Resources Mentioned DOJ case source: https://www.justice.gov/opa/pr/arizona-woman-pleads-guilty-77-million-tax-refund-fraud-s cheme IRC § 3134, Employee Retention Credit:[ https://uscode.house.gov/view.xhtml?req=(title:26%20section:3134%20edition:prelim)]( h ttps://uscode.house.gov/view.xhtml?req=(title:26%20section:3134%20edition:prelim) 18 U.S.C. § 286, conspiracy to defraud the government with respect to claims: https://uscode.house.gov/view.xhtml?req=(title:18%20section:286%20edition:prelim)%20 OR%20(granuleid:USC-prelim-title18-section286)&f=treesort&edition=prelim&num=0&ju mpTo=truel 26 U.S.C. § 7206, fraud and false statements: https://www.law.cornell.edu/uscode/text/26/7206 IRS ERC FAQs: https://www.irs.gov/coronavirus/frequently-asked-questions-about-the-employee-retentio n-credit 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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  Episode #16

  The Queen’s Refund

  Jul 31, 202612 min

  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-scheme IRS-CI conviction source: https://www.irs.gov/compliance/criminal-investigation/pennsylvania-woman-convicted-in-million-dollar-government-fraud-scheme Court record, recommendation on motion to suppress: https://ecf.almd.uscourts.gov/cgi-bin/show_public_doc?2024cr0437-84 18 U.S.C. § 1341 , mail fraud 18 U.S.C. § 1349 , attempt and conspiracy 26 U.S.C. § 7206 , fraud and false statements Beckwith v. United States , 425 U.S. 341 (1976): https://www.law.cornell.edu/supremecourt/text/425/341 Cheek v. United States , 498 U.S. 192 (1991): https://www.law.cornell.edu/supremecourt/text/498/192 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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  Episode #15

  The Twin Shell Game

  Jul 24, 202614 min

  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.

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  Episode #14

  Slow Jamz, Faster Levies

  Jul 17, 202614 min

  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-crimes 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.

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