Articles · Employee Retention Credit (ERC)
Reported article
Thirty-Four Cases, Thirty-Three Schemes, No Fraud Rate
Every federal Employee Retention Credit prosecution and civil refund fight found through July 2026, in 26 district courts, with five dollar columns that are never added together.
There is no official tally of federal Employee Retention Credit fraud. There is a run of Justice Department press releases, a smaller set of charging documents, and a smaller set still of actual court dispositions, spread across more than twenty district courts and issued over three years. The ledger below lists every federal ERC-enforcement matter we found: thirty-four matter records.
What the ledger is
Each row is one federal matter: a criminal prosecution, a stolen-check or laundering conspiracy, an ERC-receivable case, or a civil refund fight. The fields are the ones a reader needs to check the work: court, posture, a source link, and, kept strictly apart, five dollar categories. Every figure traces to a Justice Department or U.S. Attorney release, an IRS Criminal Investigation or Inspector General release, or a charging or court document. Some docket numbers and disposition dates read "not located": the public releases and free court records did not give them.1
Thirty-four records is not thirty-four schemes. Two of the rows (Candies Goode-McCoy in Nevada and Adonia Stiles, a referral source in the same conspiracy) are one criminal cluster charged against two defendants. Collapse them and the ledger describes no more than thirty-three distinct scheme clusters. A thirty-fourth defendant, Lakeibia Fannin, pleaded guilty in the same district and may belong to the same Nevada network, but nothing in the located public record confirms that link, so she is kept as her own row and the count is written as a ceiling, not a total. If the Fannin connection is ever docketed, the scheme count drops to thirty-two. It never rises to thirty-four.2
Five numbers that never add up
The ledger carries five money columns — claimed, paid, loss, restitution, and forfeiture — and they are never summed, never averaged, and never collapsed into one "fraud" figure. They measure different things at different stages of a case.
Claimed is what a scheme asked the government for. Paid is what the government actually sent. Those two diverge by orders of magnitude: Rudolph Johnson, Frantz Pasteur, and Frederick Anderson were charged by complaint in New Jersey with seeking $2,921,060,241.08 in pandemic tax credits; the Treasury issued $1,027,833.39 against that request.3 A ledger that reported the $2.9 billion as "fraud" would overstate the money out the door by a factor of roughly 2,800.
Loss is a court's or a plea's measure of harm, and the ledger splits it into alleged and adjudicated so the two are never confused; in this record every populated loss figure is an adjudicated one. Restitution is what a defendant was ordered to repay, which frequently sweeps in relief beyond ERC. Forfeiture is property surrendered. These overlap in ways that make addition meaningless: a single dollar of fraud can appear as a claim, then a payment, then a restitution order, then a forfeited car.
Loss can move independently of payment. Renata Walton and Nicole Jones pleaded guilty in an $80 million relief-fraud case that fixed an adjudicated loss of $52 million, but the located public record supplies no separate payment figure.4 Ashley Clark Ingram's $514,672.37 adjudicated loss exceeds the $388,550.75 payment because the loss calculation includes funds beyond the ERC refund.5
Identical figures create the opposite trap. Andre Summerville's $866,171 appears as payment, adjudicated loss, and restitution; Lakisha Pearson's $15,942,586.77 appears as both payment and restitution.67 The figures match because different legal questions happened to produce the same answer. Summing the columns would count the same transfer two or three times. The categories can also cross awkwardly: Tiffany Williams's $46,806,794.65 restitution order exceeds the indictment's roughly $45 million paid figure for the entire Credit Reset scheme. One is a defendant-specific sentencing finding and the other a charging-stage allegation about a wider conspiracy.8
Two more contaminations sit inside the columns. First, many DOJ figures combine ERC with the paid sick-and-family-leave credit, or with PPP, EIDL, and stolen Treasury checks; the $2.9 billion above is an ERC-plus-leave-credit number, and the ledger flags each row where the source combines them. Second, a blank is not a zero. Where the record shows an explicit finding that nothing was paid — Casie Hynes's $1.25 million in claims that yielded $0, or the attempted theft of a legitimate ERC check in Massachusetts — the cell reads $0. Where no figure appeared in the public sources searched through July 2026, the cell is empty. Reading empty as zero, or zero as empty, breaks the dataset.
Allegation and finding
Every row states its posture. A grand jury indictment or a civil complaint is an allegation — the government's untested account. A guilty plea, a jury verdict, a sentence, or an entered judgment is a finding.
Most of the ledger has at least one finding. Six criminal matters remain allegation-only, charged by indictment or complaint with no disposition located: the Thomas prison-cell scheme, Johnson/Pasteur/Anderson, Madelein Olivia, the Anand and Bessant stolen-check conspiracies, and the Robinson receivable case. A seventh row is civil — Plastic Film, LLC v. United States — where the government's counterclaim to claw back an allegedly erroneous refund has only survived the pleading stage; the court decided nothing about eligibility or amount.9
Some rows are mixed, and the ledger says so. In the Credit Reset case, Tiffany Williams has been sentenced to 36 months with $46,806,794.65 in restitution and $135,809.39 in forfeiture, and Janine Davis has pleaded guilty; the matter's headline "8,000-plus returns, more than $600 million sought, about $45 million paid" figures remain allegations against the other defendants. The restitution and forfeiture are findings; the claimed and paid numbers are not.8
No fraud rate, and no ranking without a column
It will not give a fraud rate. There is no denominator here. Thirty-four enforcement matters are the cases prosecutors chose to bring and could resource, not a random sample of the full universe of ERC claims. Divide any column by total ERC disbursements and the result has the shape of a statistic and the content of an artifact of prosecutorial attention.
It will not settle superlatives on its own, either. DOJ described the Credit Reset indictment as the largest ERC scheme charged in the United States, and that attribution is real, but by alleged claimed amount, Johnson/Pasteur/Anderson ($2.9 billion) and the Thomas scheme ($550 million) are larger, so "largest" has to name its column and its posture or it collapses. Nor is the largest charged case the largest scheme of any kind: the Treasury Inspector General for Tax Administration separately described stopping roughly $3.5 billion in potentially improper ERC and leave credits filed on freshly obtained EINs, an administrative interception that was never charged and must never be merged into the prosecution ranking.10
And it will not tell you a case's merits from its posture. The one matter that went all the way to a jury on a preparer's ERC theory — United States v. Bassett, Warr, and COS Accounting in Utah — ended in acquittal on all counts.11 It sits in the ledger with an $11 million alleged-claimed figure and no loss, no restitution, no forfeiture, because a jury found the government had not proven its case. A dataset assembled only from guilty pleas and pending indictments would delete that outcome and leave the reader believing criminal intent follows automatically from an aggressive eligibility position.
One matter, one column, one posture
Read with the columns kept apart, the ledger supports narrow, checkable statements. Leon Haynes was convicted by a New Jersey jury in November 2025 and sentenced in April 2026 to 144 months and more than $55 million in restitution, on a scheme DOJ valued at more than $170 million sought and more than $55 million paid.12 Candies Goode-McCoy pleaded guilty and was sentenced to 54 months after filing more than 1,200 returns seeking over $98 million, of which the IRS paid about $33 million, with $26,022,188 ordered in restitution.13 The Robinson prosecution is about receivables, not eligibility: it alleges the same 2021 receivables were sold twice, for advances of about $2.7 million and $4.7 million.14 Each of those is a sentence about one matter, sourced to one column, tagged allegation or finding. None of them is a total.
The ledger
Amounts are shown in the category the source assigned them; "—" is no recorded figure, "$0" is an explicit finding of nothing paid. Superscripts are defined beneath the table.
| ID | Matter (lead defendant) | Court | Posture | Claimed | Paid | Loss (adj.) | Restitution | Forfeiture | Source |
|---|---|---|---|---|---|---|---|---|---|
| ENF-001 | Bassett / Warr (COS Accounting) | D. Utah | Finding — acquittal, all counts | $11,000,000 ᵃ | — | — | — | — | official record |
| ENF-002 | Gregory (Elijah USA Farm) | C.D. Cal. | Finding — plea, sentenced | $65,300,000 | $2,769,173 | — | $2,769,173 | — | official record |
| ENF-003 | Hynes | C.D. Cal. | Finding — plea, sentenced | $1,255,703 | $0 | — | $2,376,168 ᵃ | — | official record |
| ENF-004 | Toland | E.D. Cal. | Finding — plea, sentenced | $13,400,000 | $1,950,000 | — | $2,078,462 ᵃ | — | official record |
| ENF-005 | Thomas et al. (prison-cell scheme) | E.D. Cal. | Allegation — indictment | $550,000,000 | — | — | — | — | official record |
| ENF-006 | Haynes | D.N.J. | Finding — jury conviction, sentenced | $170,000,000 ᵃ | $55,000,000 ᵃ | — | $55,000,000+ | — | official record |
| ENF-007 | Johnson / Pasteur / Anderson | D.N.J. | Allegation — complaint | $2,921,060,241.08 ᵃ | $1,027,833.39 | — | — | — | official record |
| ENF-008 | K. Williams et al. (Credit Reset) | E.D.N.Y. | Mixed — one sentenced, one plea; rest alleged | $600,000,000 ᵃ | $45,000,000 ᵃ | — | $46,806,794.65 ᵇ | $135,809.39 ᵇ | official record |
| ENF-009 | Walton / Jones (R&B Tax Express) | W.D. Tenn. | Finding — pleas (sentence not located) | $80,000,000 | — | $52,000,000 | — | — | official record |
| ENF-010 | Pearson (Unity Tax Express) | N.D. Miss. | Finding — plea, sentenced | $47,000,000 | $15,942,586.77 | — | $15,942,586.77 | — | official record |
| ENF-011 | P. Jones | N.D. Miss. | Finding — plea, sentenced | $3,800,000 | $1,422,022 | — | $1,422,022 | — | official record |
| ENF-012 | Schiele | W.D. Mo. | Finding — plea, sentenced | $1,392,716 | $478,890 | — | $130,125.09 | — | official record |
| ENF-013 | Ragan | D. Del. | Finding — plea, sentenced | $20,000,000 | $1,600,000 | — | $1,600,000 | — | official record |
| ENF-014 | Summerville | D. Del. | Finding — plea, sentenced | — | $866,171 | $866,171 | $866,171 | — | official record |
| ENF-015 | Raby / Williams | M.D. La. | Finding — pleas, sentenced | — | $4,400,000 | — | $3,158,747.51 | $2,086,998.28 | official record |
| ENF-016 | Glidewell et al. | E.D. Tenn. | Finding — pleas, sentenced | $3,400,000 | $1,806,637 | — | $1,806,637 | — | official record |
| ENF-017 | Goode-McCoy | D. Nev. | Finding — plea, sentenced | $98,000,000 ᵃ | $33,000,000 ᵃ | — | $26,022,188 | — | official record |
| ENF-018 | Fannin | D. Nev. | Finding — plea (sentence not located) | $3,500,000 | $1,400,000 | — | — | — | official record |
| ENF-019 | Stiles † | D. Nev. | Finding — plea, sentenced | $15,000,000 ᵃ | $7,000,000 ᵃ | — | $7,079,121.48 | — | official record |
| ENF-020 | D. Jackson (ghost preparer) | S.D. Ga. | Finding — conviction, sentenced | $4,112,297 | $1,567,855 | — | $1,500,000 | — | official record |
| ENF-021 | Peterson | N.D. Tex. | Finding — guilty, sentenced | $5,279,030 | $3,146,986 ᵃ | — | $3,146,986 | — | official record |
| ENF-022 | Brown (Yaya Flowtiques) | E.D. Mo. | Finding — plea (sentence not located) | — | $177,546.93 | — | — | — | official record |
| ENF-023 | Durkin | D. Ariz. | Finding — plea (sentencing scheduled) | $7,700,000 | — | — | — | — | official record |
| ENF-024 | Hubbard et al. | S.D. Ohio | Finding — convictions (one ERC role unresolved) | $4,500,000 | $207,000 | — | — | — | official record |
| ENF-025 | Eley / Whitehead | E.D. Va. | Finding — pleas (sentences not located) | $900,000 ᵃ | $649,050 | — | — | — | official record |
| ENF-026 | Ingram (nonprofit finance director) | D.S.C. | Finding — plea, sentenced | — | $388,550.75 | $514,672.37 ᵃ | — | — | official record |
| ENF-027 | Mack | E.D. La. | Finding — plea (sentence not located) | — | — | $625,310 | — | — | official record |
| ENF-028 | Dhar (tax evasion; ERC ancillary) | D. Conn. | Finding — guilty, sentenced | — | $254,203.01 | — | — | — | official record |
| ENF-029 | Tenryk / Jackson | D. Mass. | Finding — pleas, sentenced | $3,000,000 | $0 | — | — | — | official record |
| ENF-030 | Olivia | S.D. Fla. | Allegation — indictment | $7,000,000 | — | — | — | — | official record |
| ENF-031 | Anand et al. (stolen-check conspiracy) | S.D.N.Y. | Allegation — pending | $80,000,000 ᵃ | $50,000,000 ᵃ | — | — | — | official record |
| ENF-032 | Bessant et al. (stolen-check conspiracy) | D.N.J. | Allegation — complaint | $11,000,000 ᵃ | — | — | — | — | official record |
| ENF-033 | Robinson (Addiction Recovery Care) | E.D. Ky. | Allegation — indictment (pleaded not guilty) | — | $7,439,843.18 ᶜ | — | — | — | official record |
| ENF-034 | Plastic Film LLC | S.D. Miss. | Civil — counterclaim survived pleadings | — | — | — | — | — | official record |
Table notes. ᵃ The figure combines ERC with paid sick-and-family-leave credits, PPP or EIDL, Treasury and SBA funds, or non-ERC checks, and is not an ERC-only amount. ᵇ Restitution and forfeiture are findings entered against Tiffany Williams specifically; the matter's claimed and paid figures remain allegations against other defendants. ᶜ The figure is the amount two buyers allegedly advanced for the same receivables, not a government payment. † Stiles is the same Nevada conspiracy as Goode-McCoy (ENF-017) and counts once toward any scheme tally; Fannin (ENF-018) may belong to the same network, but the link is not docket-confirmed.
Notes
- The federal ERC-enforcement ledger has a July 2026 cutoff and draws from U.S. Department of Justice and U.S. Attorney press releases, IRS Criminal Investigation and Treasury Inspector General for Tax Administration releases, and freely available charging and court documents. “Not located” means those sources did not supply the item, not that it does not exist. ↩
- The ledger identifies Goode-McCoy and Stiles as defendants in the same Nevada conspiracy and therefore one scheme cluster. Fannin's possible relationship to that network is not confirmed in the located docket record, so the published ceiling remains no more than 33 distinct clusters. ↩
- U.S. Attorney's Office, District of New Jersey, "Three Charged for Fraudulently Seeking $2.9 Billion in COVID-19 Tax Credits," justice.gov (original), and the underlying federal complaint, United States v. Johnson, Pasteur, and Anderson (D.N.J.). The complaint alleges the defendants filed roughly 131 forms in the names of sham entities claiming $2,921,060,241.08 in ERC and paid sick-and-family-leave credits, against which the Treasury issued $1,027,833.39. This is an allegation; the $2.9 billion is not an ERC-only figure. ↩
- U.S. Department of Justice, “Tennessee Tax Preparer Pleads Guilty to $80M Pandemic Relief Fraud Scheme”, United States v. Walton and Jones (W.D. Tenn.): guilty pleas and an aggregate $52 million adjudicated loss; the located release states no separate amount paid. ↩
- U.S. Attorney's Office, District of South Carolina, “Former Nonprofit Finance Director Sentenced for Theft of Government Funds”, United States v. Ingram: guilty plea, $388,550.75 paid, and $514,672.37 adjudicated loss including funds beyond the ERC payment. ↩
- U.S. Attorney's Office, District of Delaware, “Philadelphia Man Sentenced to 18 Months in Federal Prison for Government Theft”, United States v. Summerville: guilty plea and $866,171 recorded as amount paid, adjudicated loss, and restitution. ↩
- U.S. Attorney's Office, Northern District of Mississippi, “Marshall County Woman Sentenced to 52 Months in Prison for COVID IRS Fraud”, United States v. Pearson: guilty plea, $47 million claimed, and $15,942,586.77 recorded as both amount paid and restitution. ↩
- United States v. Williams et al. / Credit Reset, No. 2:25-cr-00020-GRB (E.D.N.Y.); DOJ Eastern District of New York indictment and releases. Tiffany Williams: 36 months, $46,806,794.65 restitution, $135,809.39 forfeiture. Janine Davis pleaded guilty on May 14, 2026, with sentencing set for September 25, 2026. The "8,000-plus returns, more than $600 million sought, about $45 million paid" figures are indictment allegations except where a specific plea or sentence has been entered. ↩1 ↩2
- Plastic Film, LLC v. United States, No. 5:25-cv-00030 (S.D. Miss.), June 2026 order allowing the government's 26 U.S.C. §§ 6532/7405 counterclaim to recover an allegedly erroneous ERC refund to proceed past the pleadings, as reproduced by Justia (original). The order did not find the taxpayer ineligible or fix any loss amount. ↩
- Treasury Inspector General for Tax Administration, "TIGTA Identifies Fraud Scheme, Alerts IRS to Prevent $3.5 Billion in Potentially Improper Pandemic Tax Credits," April 2024, tigta.gov (original); also reflected in TIGTA's Semiannual Report to Congress (Sept. 2024). This was an administrative interception of claims filed on newly obtained EINs, not a charged criminal case, and is not part of the prosecution ledger. ↩
- U.S. Attorney's Office, District of Utah, "Utah County Residents and an Accounting Business Charged in $11 Million COVID-Related Tax Fraud Scheme," justice.gov (original); jury acquittal on all 25 counts reported September 25, 2024, e.g., "Jury finds Provo businessmen not guilty in $11M COVID tax fraud case," KSL.com (original). The $11 million was an alleged claimed amount combining ERC and leave credits; the judgment of acquittal adjudicated no loss. ↩
- United States v. Haynes, No. 2:24-cr-00232 (D.N.J.); DOJ, IRS Criminal Investigation, and SSA Office of the Inspector General releases (the sentencing release also orders more than $55 million in restitution): jury conviction, "New Jersey Tax Preparer Convicted for $170 Million COVID-19 Tax Credit Scheme," Nov. 20, 2025, oig.ssa.gov (original); sentence of 144 months, "New Jersey Tax Preparer Sentenced to 144 Months in Prison for $170 Million COVID-19 Tax Credit Scheme," Apr. 8, 2026, oig.ssa.gov (original). More than $170 million sought and more than $55 million paid, per DOJ. ↩
- U.S. Attorney's Office, District of Nevada, "Business Owner Sentenced to Over Four Years in Prison for $100M COVID-19 Tax Credit Scheme," justice.gov (original); IRS Criminal Investigation, "Business owner sentenced to over four years in prison for $100m COVID-19 tax credit scheme," April 7, 2026, irs.gov (original). More than 1,200 returns seeking over $98 million; the IRS paid approximately $33 million; 54-month sentence; $26,022,188 restitution. ↩
- U.S. Attorney's Office, Eastern District of Kentucky, "Addiction Recovery Care Founder Indicted for Wire Fraud and Money Laundering," justice.gov (original). The indictment alleges the same 2021 ERC receivables were sold to two buyers, generating advances of roughly $2.7 million and $4.7 million; Robinson has pleaded not guilty. These are allegations. ↩
Primary sources used in this article
- The normalized federal ERC-enforcement ledger (34 matter records; research cutoff July 2026), compiled from the public sources below
- Federal complaint and DOJ D.N.J. release, United States v. Johnson, Pasteur, and Anderson ($2.9 billion charged; $1,027,833.39 issued)
- DOJ D.N.J., IRS Criminal Investigation, and SSA-OIG releases, United States v. Haynes (Nov. 2025 conviction; 144-month sentence, Apr. 8, 2026)
- DOJ D. Utah charging release and contemporaneous verdict coverage, United States v. Bassett, Warr, and COS Accounting (acquittal on all counts, Sept. 25, 2024)
- DOJ D. Nev. and IRS-CI releases, United States v. Goode-McCoy (54-month sentence; $26,022,188 restitution)
- DOJ E.D.N.Y. indictment and releases, United States v. Williams et al. / Credit Reset (Tiffany Williams sentenced; Janine Davis plea)
- DOJ E.D. Ky. release and indictment, United States v. Robinson / Addiction Recovery Care (receivable double-sale allegation)
- Court order in Plastic Film, LLC v. United States, No. 5:25-cv-00030 (S.D. Miss.)
- TIGTA press release and Semiannual Report to Congress on the $3.5 billion EIN-based claim scheme (administrative interception)