Court filing

Motion to Vacate Attachment — USA v. Torjagbo (Dkt. 259.1)

Filed January 27, 2026 in USA v. Torjagbo; one of 189 filings from this case.

Record facts

Court	U.S. District Court for the Northern District of Georgia
Filed	2026-01-27

U.S. District Court for the Northern District of Georgia · No. 1:22-cr-00171-MLB-RDC · Doc. 259-1 · 2026-01-27 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
KARL LUCIUS DELANO a/k/a
CARL DELANO TORJAGBO
V
UNITED STATES OF AMERICA
MOTION TO VACATE OR SET ASIDE CONVICTION
PURSUANT TO 28 USCS.2255
FILED IN CLERK'S OFFICE
u.s.o.c. -Atlanta
JAN 2 7 2026
KEVIN P WEIMER. Cieri<
B~
utyCterl<
COMES NOW The Defendant, KARL LUCIUS DELANO, files this motion PRO SE
pursuant to 28 USCS.2255, requesting the court to vacate the convictions on all 10
counts of the Indictment on the following grounds.
BACKGROUND
On July 1st 2025 Mr. Torjagbo was indicted by a Grand Jury on a 10 count 3rd
superseding indictment. The charges include Bank Fraud, wire fraud, concealment
money laundry and transactional money laundry. On July 2l51 2025, the case proceeded
to trial and on July 25th 2025, a Jury convicted Mr. Torjagbo of all 10 counts of the
indictment. On January 26th of 2026 Mr. Torjagbo was Sentenced. Pursuant to 28
USCS.2255 paragraph (b ), If a court finds that there has been such a denial or
infringement of the constitutional rights of a prisoner as to render a Judgment vulnerable
to collateral attack, the court shall vacate and set aside and shall
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Discharge the prisoner or re sentence him as may appear appropriate. It is my assertion
that three of my constitutional rights, 14th amendment, 6th amendment and 5th
amendment rights were infringed upon pretrial and during the trial. In support of my
motion, I state the following.
VIOLATION OF 14TH AND 5TH AMENDMENT RIGHTS
1. Use of Fabricated Evidence; The evidence presented and used by prosecutors from
Turbo Tax was fabricated (Gov Exh220). Each time a tax return is submitted to the IRS,
the agency generates a submission code. A look at the events that occurred in the IRS
data base from the time the first return was submitted, till a refund was issued shows
only two submission codes. (Exh3 pg9 and pg17 bottom). It also shows the number of
times a file was rejected and in the case of Social Security Number (SSN) ending in
0540, only one occurrence (Exh3 pg9). Furthermore, Turbo Tax issued only two
certificates of rejections. One for SSN ending in 6010 for 02/06 6:05pm (Exh2) and one
for SSN ending in 0540 at 6:15pm on 02/12 (Exhl). The excel spread sheet was
fabricated to make it appear to the Jury and the court that on 02/06, two submissions one
each were made for SSN 6010 and 0540 and both were rejected the same day (Gov
Exh202 Pgland 2 Line 1 and 2). Then on 02/12 another submission was made for
both SSN 6010 and 0540 at 6:15pm and 6:37pm (Gov Exb220 pgl and 2 Line 4 and
5) misleading the jury to believe, this had to be done by one person or if there were
two people, they had to have been together. The Turbo Tax expert testified that the
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Tax returns were processed in batches (Exhl0 Trl Trsrpt Vol 3 pg. 621 line 1-9). What
actually happened was on 02/06 SSN 6010 was submitted and rejected at 6:05pm
(Exh2). A submission was made for 0540 on 02/06 but that was not processed until
02/12 and was rejected at 6:15pm (Exhl). A subsequent submission was made for 6010
on 02/12 at 6:37pm (Exh4) which was accepted, and on 02/13 at 08:42am, a re-
submission was made for SSN ending in 0540 which was also accepted (Exh5). In
summary lines 2 and 3 are fabricated rejections and lines 4 and 5 are fabricated
submissions (Gov Exh220 Pgland 2). Also a look at the IRS data base shows that the
rejection code FW 205-01, which means the tax filing was rejected because the EIN was
not valid for the tax year, occurred only once on February 12 and remained at an
occurrence of 1 until the refund was issued (Exh3 pgll and pg9). My account of what
happened was, I asked Andrea previously if she could help with filing my taxes. She
promised to do it but was preoccupied with other things and kept giving excuses. The
day before I was heading for Miami, while I was in the subdivision clubhouse, she came
and filed the taxes. She thought I had already left for Miami so she did not bother
calling. I had previously told her all the information required was on my laptop and she
mistakenly used the information for the social security number ending in 6010. When I
came home from the clubhouse, I filed the tax return using my correct social security
number ending in 0540 not knowing that she had already filed a return. I headed for
Miami the next morning and was there for about 5days. On my way back, I got an email
and text alert that my tax return had been rejected by the IRS because the Employer
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Identification number (EIN) used was issued in 2021 and could not be used for a 2020
tax return. I got home late that night and the following morning which was 02/13,
resubmitted the tax return using the EIN that was issued in 2018. Andrea got the same
message earlier and came back to the home office on 02/12 and resubmitted the one
ending in 6010 with the EIN issued in 2018. When I spoke to her later that day she
advised me of what happened. I called Turbo Tax and attempted to cancel the one Andre
filed but was told it had already been accepted and I would just have to wait until the
IRS contacts me. The account of what happened matches the IRS database and Turbo
Tax certificates of what happened. By the way Andrea has been working as my assistant
since 2017. She typically works from my home office or on site at the mining fields. She
has a key to my home office and there is nothing all of a sudden or strange about her
coming to my home. My previous attorneys Kendall Silas, Jodi Yoshi and the paralegal
Sarah for 2 years knew about Michael Lee and his brothers as well as Andrea Lewis, and
so did my current attorney Leigh Finlayson.
2. False Testimony by Turbo Tax Expert; The Turbo Tax expert Mr. Davis, testified
falsely to support the fabricated evidence further misleading the Jury and the court. He
testified (1) that the tax submissions were processed in batches. (2) if there is a rejection
the file is sent back to the applicant and only the applicant can correct the error. (3) An
error or rejection code is generated only if an applicant submitted a file.( 4) An internal re
submission of a file by Turbo tax does not generate a code.(5) he also testified that codes
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on the excel spread sheet were generated by a computer ruling out the possibility of
human error (Exhll Trl Trscrpt Vol 3 pg. 654 line 5-25 pg. 655 1-25 pg. 656 1-25),
which is false because the only codes generated by the submission of files to the IRS are
02/12/2021440893202103704ANJ07 and 02/13/2021 440894202104303VIKQ6 (Exh3
pg9,pg17). Any other codes or submission and rejection on the excel spread sheet for
SSN 0540 to the IRS was fabricated by someone. Furthermore, prosecutors reinforced
the fabricated evidence and false testimony in their closing arguments of what they
wanted the Jury and Court to believe happened (Exh12 Trl Trscrpt Vol3 pg. 1157 line 5-
25 pg. 1158 1-25). A false testimony is one that is given concerning a material matter
with the willful intent to provide false testimony rather than as a result of confusion,
mistake or faulty memory. Both the prosecutors and the Turbo Tax expert knew there
were only two submissions and one rejection for SSN 0540 since Turbo Tax issued the
certificates of rejection. The prosecutors also knew this since they had this information
in the IRS special agent report in the discovery. The fabrication and testimonies were
done with the intent to mislead the Jury that it was the same person who resubmitted or
edited the files since they were within 22 minutes of each other and even if there were
two people, they had to be together (Exh13 Trl Trscrpt Vol3 pg647 line 2-9). This is the
equivalent of making up evidence to place someone on a murder scene, when they were
in fact somewhere else.
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3. False Testimony by SBA and Chase Bank Experts; Both the SBA expert and the
Chase Bank expert, Mrs. Drake and Mrs. Carpenter falsely testified that in order to be
eligible for the PPP loan, the business had to be located in the United States (Exh14 Trl
TrscrptVol3 pg. 501 linel- 8 pg510 1-5 pg. 51313-25 pg. 514 21-25 pg. 55714-17).
Both of them of them also falsely testified that the documents that were required to be
submitted to the Bank for the loan application, had to be filed with the IRS (Exh15 Trl
Trscrpt Vol3 pg. 517 lines 8-11 pg. 564 pg. 1-10). Once again these statements were
made under oath with the willful intent to manipulate the Jury, and to mislead them to
believe that applying for a loan that I knew I was not qualified for, Is in itself a knowing
and willful misrepresentation of material facts to Chase Bank. There is nowhere in the
rules of the PPP program that states the business had to be located in the United States.
It only states the funds were to be used for workers whose Principal Place of Residence
is the United States (Exh6 pg. 12 para f). Expat workers have their Principal Place of
Residence in the United States but work abroad or overseas. If congress intended that
the business had to be located in the United States, then it should have said so in the
rules. And if it was intended for workers to be working on US soil, it would have said so
in the rules. An average person applying for the loan should not have to guess what
congress intended. Is as if they a bending the existing rules just to convict someone.
There is nowhere in the documentation instructions that states documents provided for
the loan application had to be filed with the IRS prior to submitting them. The PPP
portal opened in January of 2021 and closed in March of 2021 (Exh16 Trl Trscrpt Vol3
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pg501 line 25 pg502 1-9). The portal for filing 2020 tax returns did not open until Mid-
February of 2021. Which means all the applicants from January of 2021 to Mid-
February which is about one fourth of the applicants, submitted estimates of their taxes.
The instructions given by Chase bank to applicants only require you to submit estimates
if you had not yet filed your taxes. So it was not like Mr. Torjagbo was the only
applicant who submitted estimates of his Taxes to defraud or deceive the Bank. Was I
late in paying 940 and 941? Yes. Were the estimates accurate? Yes, they were. Would I
have paid and filed the 940,941 if the tax laws obligated overseas located business to do
so? Yes, I would have.
To establish due process violation based on the use of fabricated evidence and perjured
testimony, the movant must prove that (1) Fabricated evidence and false testimony was
used, (2) The prosecutors should have known that the statements or evidence are false or
allowed it to go on uncorrected, (3) The false testimony or fabricated evidence could
have affected the Jury verdict. All the instances stated above, meet if not exceeds these
requirements. Napue V United States 360 US 264 259. 79S ct 1173 3L ED 2d
1217(1959).
4. False Testimony by IRS Agent; The rigorous checks that a Tax return goes through
before a refund is issued is evident when you look at the evidence presented in this case.
The first two returns filed, one by Andrea mistakenly with SSN ending 6010 and DOB
09/08/75 with a Houston address, and the other by me SSN 0540 Dob 09/10/79 and a
Georgia address were processed by two different agents (Gov Exh202 pg3 Line 1 and 2).
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They were both rejected because the agents checked and realized that the EIN though
valid was not applicable for the Tax year. Other checks that these agents performed will
be to check if the SSN was valid. Another check the agents did was to see if the
applicant owed any taxes from previous tax year (Exhl 7 Trl Trscrpt Vol3 pg. 709 lines
24-25 pg. 710 1-9 pg. 740 4-17). However, the most critical check which is whether
the applicant actually paid taxes, the agent claims in his testimony they just assume
the information is correct and the numbers on the 1040 just rolls over (Exh18 Trl Trscrpt
Vol3 pg687 lines 21-25). If this is true, then the agents that processed the return would
have assumed the EIN's were valid. They would have assumed the applicant does not
owe any money, and most importantly they would have made the same assumption in
the filing ending in 6010 which is roll the numbers from the 1040 over and a refund
check would have been issued in this filing as well. The only reason why a refund was
issued for the filing with SSN ending in 0540 was because a wire transfer of a payment
referencing SSN 0540 was received and credited to that account (Exh34). Another thing
I would like to highlight is that Mr. Salvatore did not process the EIN applications, he
did not process my tax returns either. He is merely looking at documents after the fact
and giving testimonies in line of what the prosecutors want the Court and Jury to believe
happened. This pattern of False testimonies even when the hard paper evidence says
another, is the same as what the SBA expert and Chase Bank expert did. With the
specific intent of manipulating the Jury or outcome of the Trial.
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Violation of 6thand 5th amendment ri hts due to Ineffective assistance of counsel
1. Refusal to present evidence in the discovery that would prove or expose
fabricated evidence used by prosecutors; When my attorney revealed to me the
exhibits that the prosecutors intended to use at trial, I expressed concern about the excel
spread sheet being presented, versus my recollection of what happened or resulted in the
duplicate Tax return filed by my assistant Andrea Lewis. The Fabricated evidence
presented made it appear that both Taxes for Social Security numbers ending in 6010
and 0540 were filed or edited and resubmitted within 22 minutes' intervals 6: lSpm and
6:37pm respectively. I went digging through the IRS special agent report in the
discovery material provided by prosecutors and found evidence that supported my
suspicion. The Turbo tax certificates of rejection and a detailed account of events
that occurred from when the Tax returns were submitted until the refund was
issued in the IRS data base (Exhl,2,3,4and5). I brought the evidence to my attorney's
attention and he concurred that there was something fishy about the spread sheet, but
brushed it off and said we can look at those later. I brought it to his attention again the
second time right before trial started expressing my concern that this might mislead the
Jury, again he agreed with me but said he was tired and we had several other evidence
and recordings to look through so we can deal with that later. Trial started on July 21st
and on the 4th day of trial, I brought the exhibits to the court room. They were in a bright
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Green folder and the rest of all the other evidence in a bright Red folder. During the
short break, I brought this to his attention again. This time his response was "I don't
want to get into all of that you can do that on your own". After lunch I asked him again,
but this time I said we don't have to go through the evidence in the IRS data base just
the two certificates of rejection issued and certified by Turbo Tax. This time he got angry
that I brought this up again and said "if you want to do that, do it on your own. I already
told you I don't want to get into that". He then got up and abruptly left the defense table
and started talking to some unknown people in the back of the room. These actions are
equivalent to the flat out refusal to defend a client when there is clear evidence that
evidence being used by prosecutors against his client were fabricated.
2. Failure to challenge validity of questionable evidence used by prosecutors against
the defendant; Soon after I received the PPP loan and after I had transferred $3 million
to my PNC bank account, my Chase bank account was frozen. After calling Chase bank
numerous times, I was asked to present additional evidence in order to unfreeze the
account. The Customer Service Representative mentioned a number of documents
including an EIN letter that was needed. I went to the Chase Bank on chapel hill road in
Douglasville Georgia, and gave them a copy of the EIN letter that the IRS gave me when
I applied for it.
Prosecutors presented a letter that they claimed was altered or bogus because
1. The address was spelled wrongly in the data base, Leatherly instead of Leatherleaf
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2. The controlling name was different, KREM instead of TORJ
3. The letter bore semblance to another EIN letter sent by the IRS so it had to be that
letter that was altered.
4. EIN letter had no way of reaching me because the address was wrong. (Gov Exh106).
5. She also claimed the date on the letter was the same as the one which it bore
semblance to. That is categorically false. The date on the letter is 2018 and for Tax year
2019 (Gov Exh106). Also she made some false claims that I stated the post office
opened the letter and changed the address. That is false as well. I said if you put a wrong
zip code on an address, the post office can figure it out (Exh20 Trl Trscrpt Vol4 pg. 1053
lines 3-20). I expressed concern about this evidence to my attorney but his response was
"I don't think the Jury will care too much about this. Kremkov is Carl Delano Torjagbo
and Carl Delano Torjagbo is Kremkov. If the EIN was fake, then that would be a
problem". I proceeded to explain I had no way of altering a printed letter. That would be
like altering this very motion you are reading right this moment. The only way that
could be done was if I had a letterhead from the IRS with all of its security features in
order to conjure up something like that. The other issue is there are no stamps or
markings from the Bank that show that this was the actual document that I presented to
the Bank. All other documents example the ones submitted to chase bank had the SBA
stamps or makings to show these were the actual documents submitted (Gov Exhl0l pg.
10). The only true way to actually know if the letter had been altered is if prosecutors
had a copy of the actual letter sent to me from the IRS and compared it to the one I
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submitted. The IRS agent testified that they do not have a copy of the original letter that
was mailed to me (Exh19 Trl Trscrpt Vol3 pg681 Lines 20-25). Just because the letter
bares semblance to another from the IRS, does not mean it was altered to look like that.
And also, supposing the prosecutor's hypothesis was correct, and the letter never made it
to me because the address was incorrect. The only way for me to know that I had an EIN
number ending in 1377 was if I received a letter from the IRS telling me so. I was
notified via mail with a hard copy letter for all the 3 EIN' s I applied for. What I believed
most likely or probably happened was the data base had to be either deliberately
altered or maybe accidentally altered during an address change to cause a
mismatch. Knowing everything I just told him, you would expect my attorney to raise a
strong objection to the use of that evidence or challenge it so that its excluded. Just like
the preceding example he refused to do anything. Not even a rebuttal on cross
examination. The only thing he did that was close to saying something was in his closing
arguments, where he said "prosecutors want you to believe that the government does not
make mistakes". One thing is for certain though, the EIN ending in 1377 was at some
point under Kremkov.
3. Failure to properly or adequately prepare expert witness; My attorney Mr.
Finlayson called an expert witness Dr. Owusu to testify on my behalf regarding family
mining or small scale mining business in Ghana. He failed to qualify him as an expert
first of all, and also failed to ask the witness if he had any knowledge of pay rates of
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Chinese co-operated mines in Ghana. In his testimony, he eluded to the fact that the
Chinese co-operated mines had all kinds of sophisticated equipment, but did not know
how much the pay rate was (Exh22 Trl Trscrpt Vol4 pg974 Lines 2-23). According to
Mr. Finlayson, Dr. Owuso was to testify on a limited basis on the existent of small scale
mines in Ghana and the number of employees (Exh23 Trl Trscrpt Vol4 pg967 1-15). Yet
when prosecutors led the witness and started asking questions about pay rates from a
BBC article that the prosecutor claimed he read, Mr. Finlayson failed to object even
though this was outside the scope of what the witness was allowed to testify on. This
article was never presented to the Jury, and his testimony about the average pay of small
family owned mines that employ teenagers of $500 a month, is no way in comparison to
a small scale mining business with a multi-million-dollar investment from a Chinese
super-pack whose production rate averages a 100 kilos of gold a month. Furthermore,
the Amalgamation methods and sandbag washing methods that Dr. Owuso is familiar
with and describes in his testimony, are not methods used by Kremkov (Exh24 Trl
Trscrpt Vol4 pg. 977 lines 13-20 pg978 5-23). Those are crude methods and outdated
methods. Put it plain and simple, that testimony should not be allowed and its
misleading to the Jury in the sense that it would cause them to believe that the pay rates
for Kremkov Industries were somewhat exaggerated to deceive the bank. The price of 1
kilo of gold in 2019 was $78,000 per kilo. This means a mining business of Kremkov's
caliber, produces $7.8 million worth of gold monthly. A handful of these Chinese co-
operated mining business's pay between $45 to $50 an hour. We have sophisticated
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equipment like drones with ground penetrating radars, cable lifts, jack hammers, fork
lifts, mining carts and so forth that result in a faster production rate while maintaining
the status of a small scale mining business. A comparison with other family mining
business who have no special equipment and scourer the land aimlessly looking for gold,
with a production rate of few kilos a year, pay far less and is not a Just comparison.
Same concept as a commercial pilot flying a Cessna Caravan who makes about $2500
per month because he can only carry 6 passengers. The same commercial pilot flying a
B777 makes $20,000 per month because he can carry more passengers. A very big
difference in pay rates. Furthermore, online research shows pay rates range from
$90,000 to $160,000 per year according to Mining Review Africa and World Bank, with
Chinese co-operated mines paying as high as 60% more than domestically owned and
operated mines in Africa. This falls in line with what we paid our employees, which is
about a Net pay of $60,000-$70,000 after taxes (Exb8 pgl pg2 pg3).
4. Failure to properly cross examine IRS agent; I expressed concern to my attorney
about how prosecutors might cause the IRS agent to give a one sided testimony or half
the truth that could be very misleading to the Jury. My concern was the estimates of my
Tax liabilities submitted to Chase Bank (940, 941) which I ended up not filing due to
foreign earned income tax laws, could be twisted or misconstrued to make it look like I
was being deceptive and did not pay any taxes at all. My previous attorney Kendall Silas
warned of this in his last meeting. He stated the prosecutors IRS agent was going to take
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the stand and testify that he cannot find my tax payment regardless of whether I made
the payment. Also present at that meeting was attorney Jodi Yoshi, Paralegal Sarah and
an IRS agent that worked for the Federal Defender's office. I took the threat or warning
seriously so the first thing I did when my current attorney Mr. Leigh Finlayson took over
the case was, explain the situation regarding this issue and tried to make the case to him
that we needed an expert witness. Someone to testify on the defense side on how the IRS
handles revenue generated inside the United States (Internal Revenue), and revenue
generated outside the United States (External Revenue). Any income earned outside the
united states which exceeds the threshold to be exempted from foreign earned income is
taxable (more than approximately $130,000 a year Exh9 pg4). Typically, the tax owed
due to income in excess of this amount is payed individually via wire transfer, the IRS
free debit system or check. Your IRS tax transcripts shows all records of payments
made to the IRS (Exh9 pg. 6). You are told to keep records of your wire transfer or
check as proof of payment in case you are audited. A search for records for an employee
working for a foreign based company will yield no records found since their employers
do not file W2, W4 1099 or 940and 941 with the IRS and Social Security administration.
A good example is my Tax returns while working for Fly-Dubai Airlines (Exh40).
Another example is Hunter Biden. He worked for a Ukrainian Energy company and was
payed millions of dollars. Since he made more than the Foreign income exempt
threshold, this income was taxable. Hunter had to make that payment individually and
any search of records for W2 1099 940 and 941 will yield no records because none was
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filed with the IRS. Only records will be Hunter's Bank records or wire transfer records
after the payment is credited to his account. This contrast needed to be made clear to the
Jury and the court that the 940 and 941 submitted by me to Chase Bank were estimates,
per Instructions from the Bank to loan applicants stating estimates could be submitted if
Taxes had not been filed yet. Upon a later review of the laws regarding these filings
with my assistant, we came to the realization that 940,941 and W2 were not
required to be filed or paid with the IRS, if the workers were employed and worked
outside the United States. The employee's had to pay this individually. I also explained
my Tax filings. The approximately $10 million made in 2020 was income generated
from the trade of Gold, and the loss of $12 million reported as loss in excess of $10
million, was the cost of Environmental impact assessment, mining exploration and 3
months of labor cost prior to getting to the Gold. As one who was paying Taxes as an
individual, my book keeping software only tells you what your Tax liability is based on
how much you earned. The software is not meant to replace the IRS. Based on what it
said, I made that payment to the IRS via wire transfer through Michael Lee as an
individual, the only difference is I happened to have an EIN number. Mr. lee paid all
transactions such as payroll and equipment purchases himself to make sure every dollar
that was invested was used for the right purpose. I simply just paid him back in Gold.
My attorney agreed this was critical and it was a good idea to get an expert to testify in
this regards. He also eluded to the fact that the IRS agent for the government will mostly
testify to things that favored the government's case. About 3 weeks to trial, he visited
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and told me he wanted to continue the trial for October because the Pro Bono money
for experts had run out. He also said there will be no more money until October but
Judge Brown will not agree to a continuance. So I told him the best way out was to draw
out answers we were seeking for the Jury to understand the difference. I wrote a
memorandum titled "Angle of Defense" based on what I knew from my personal
experience and from consultations Andrea and I had with Tax firms, so he could craft or
ask simple questions like
1. Does the IRS handle foreign earned income differently
2.Are the records treated differently or are those records kept after the account is
credited
3. Do foreign base companies have to pay or file 940,941 and W2
4. Was there anything wrong with the way Mr. Torjagbo filed his taxes
5. Without an Audit can you say that Mr. Torjagbo committed any Fraud as to the
information on his tax returns. Further consultations with other IRS agents explain why
the payment could not be found by Mr. Salvatore the prosecutor's agent. In his
testimony, Mr. Salvatore explained how a 1099 captures anything under a social security
number. However, that has to be reported or filled out by someone. A Financial
institution, self-employed person, Casino, Lottery company and so on. This applies to
revenue earned inside the United States as foreign based organizations are not
obligated to do so (Exh25 Trl Trscrpt Vol3 Pg703 lines 17-21). It does not show wire
transfer information or check payments made directly to the IRS from any of these
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entities. So if he runs a check on payments or wire transfer made by me to the IRS, he
would not find any information or it would yield no results (Exh36 Trl Trscrpt Vol3
pg686 lines 1-4). The same applies to W2, W4, 940 and 941, which is the forms that
employers fill out and file with the IRS regarding how much taxes they withheld from
an employees pay check, and what they paid to the IRS. If we take a U.S based company
like PNC Bank which filed 940 and 941 with the IRS, a search using the companies EIN
number will only show what the company filed on its 940 and 941 but not the actual
payment. In order to get to the actual payment record, there is something called a
Master Payer Account which companies that make scheduled payments to the IRS are
required to have on file. Basically a Master payer account is an account where payments
are drawn from, sort of like having a credit card on file, or bank account number on file
with your utility company to pay your electric or phone bill (Exh27pg2 and pg3). So
let's just say PNC filed a 940 stating it withheld $4 million from 1000 employee's
paycheck and that money was paid to the IRS in the first quarter of 2022. If an Agent
wants to track down or find the actual payment record, he has the account number from
which the payment was made on file which is the Master Payer Account, the amount that
PNC paid, and the date when that payment was made. He can search the records and
find that actual payment record. Also the employer would file a W 4 with the Social
Security Administration with the name of each employee, and the exact amount
deducted from their income using their Social Security number. Let me stress again that
this is not required for foreign based companies which Kremkov was up until 2021.
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 18 of 134

Let's take another example Mr. Zeke a U.S citizen who works for Sukhoi Design Bureau
based outside the United States. In 2022, Mr. Zeke makes $250,000 and is subject to
taxation since he makes more than the allowed threshold for foreign tax exemption. So
in 2022, he owes the IRS $10,000 in withholdings which he decides to pay via wire
transfer. When the agent who processes the payments receives the wire transfer, he
credits Mr. Zeke's account using his social security number. Since that payment was for
tax withholdings, it will be logged or coded as code 806 which is the IRS code for
payments credited for tax withholdings (Exh34). Let's say a year later an IRS agent
decides to Audit Mr. Zeke to see if he actually paid taxes that he filed on his W2. Now
since this is not a regular scheduled payment and just an individual randomly made
payment, there is no requirement for a Master Payer Account to be on file with the IRS,
or the IRS does not keep that account information on file once the payment is credited.
This is similar to when I was working in the UAE as an Airline Pilot for Fly Dubai
Airlines or the Income from Kremkov Industries (Exh40). Note that the income is still
listed as W2 wages on the Tax returns, and any taxable income will be listed as Tax
Withholdings, however Fly Dubai Airlines did not fill out 1099, W2, W4, 940 or 941
with the IRS since it is not obligated to do so as a foreign based entity. So in order to
search for the actual payment, the Agent will need the account number from which the
wire transfer was made, the amount, and the date, to effectively find the record of
payment. In my case, Mr. Salvatore does not have the account information that Mr. Lee
used to pay for my tax withholdings. I don't know that account number off the top off
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 19 of 134

my head either. With the computer that had the information stolen, and me not able to
reach Mr. Lee, there is no way he can find that information. When asked if he knew how
payments were processed and logged by the IRS, he testified that he has no knowledge
of how payments are processed (Exh30 Trl Trscrpt Vol3 pg. 732 lines 1-25 pg. 733 1-25
pg. 734 1-4). One thing is certain though, a payment was received by the IRS
referencing my SSN ending 0540 for Tax withholdings for Tax year 2020. Based on that
payment, the agent processing wire transfers or payments credited my account with SSN
0540 which was coded as 806 for Tax withholdings payment. A refund was issued for
the SSN 0540 but non for SSN 6010 since there was no such payment for this SSN.
The IRS will not credit an account unless a payment is received for that account
(Exh9 pg. 7) This was mention in my memo to Mr. Finlayson in my push to have him
get an Agent to testify on the defense side but that did not happen. His cross examination
fell short of drawing this contrast or providing a better insight to the Jury and the Court.
During cross examination, he appeared not to want to ask any questions to draw this
contrast to the Jury. When he came back to the defense table, I wrote down a number of
questions for him to ask the agent but he only asked one. He asked "can you make a
payment via wire transfer or check to the IRS".
5. Refusal to Subpoena or obtain information he knew was favorable to my
defense; On the first day I met with Mr. Finlayson, I had a memorandum written to him
requesting him to subpoena
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 20 of 134

1. The documentation Instructions Chase bank gave to applicants applying for the PPP
loan
2. Letters sent by Chase Bank warning borrowers of deadlines of when to apply for loan
forgiveness.
I did so because my previous attorney Kendall Silas previously told me he saw the
letters I was referring to in the discovery. However, when I looked through all the
discovery material, I could not find the letters nor the instructions. I immediately
suspected a Brady violation, so I requested Mr. Finlayson to subpoena those
documents. Chase Bank expert witness did testify that those letters were sent (Exh31 Trl
Trscrpt Vol3 pg607 lines 19-23pg608 1-2). The content of the letter was important since
they said something to the effect that, if one does not apply for forgiveness by a certain
date, the loan becomes a regular loan that the applicant had to repay on their own. It also
mirrored some of the examples that the SBA will direct you to repay the loan, if let's say
you borrowed money for one McDonald but used the money for another one. I also
received a letter stating my first loan payment was due on Aug 10 since I did not apply
for forgiveness but was detained before then. The point I am trying to make is that these
letters, Instructions and regulatory material, were pivotal in my decision to use some of
the loan proceeds to expand Flying Jack. Put it plain and simple, I would have returned
the money to Chase Bank if it were not for the information I received and read from the
Bank and SBA. It is also critical for the Jury and the Court to know this because if
the crux of the crime or what made the conduct criminal was knowingly and
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 21 of 134

willfully deceiving the bank, then this is adequate prove that my actions were not
some sort of a grand scheme to knowingly and willfully defraud the Bank, but
rather my actions and decisions were a result of the information I received.
Prosecutors will argue that I spent $100,000 before I got my Tax refund and that was
from PPP funds to get into a binding contract for my house and pay some bills. That is
true, however this $100,000 was my paycheck in accordance and in compliance
with the program (Exh6pgll para e sub para ii). One is allowed to spend their
paycheck on whatever the desire. Mr. Finlayson action also falls under exculpatory
evidence. He relied solely on evidence provided to him by prosecutors, and made no
effort whatsoever to investigate anything even after he was repeatedly told of the
existence of evidence favorable to the defendant. Failure to investigate a critical
source of potentially exculpatory evidence presents a case of constitutionality
defective representation. United States Vs Baynes 622 F2d 66 69 (3rd Cir 1980).
6. Failure to call witness; I told my attorney, Brahim Ganzou and Kate Flourney are
two potentially good witnesses that can testify in my favor as to the use of funds in
Flying Jack, and corroborate a lot of the things I did including my train of thoughts. I
discussed a lot of things in company meetings with my workers. He agreed that was
good because a lot of the case had to do with my intentions and what I was thinking. As
we got closer to trial, he told me he could not locate Kate Flourney and Brahim Ganzou
did not want to testify. Brahim Ganzou told him the exact opposite. He told Mr.
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 22 of 134

Finlayson he would be glad to testify regarding things that happened in Flying Jack such
as letters I received, use of funds, and anything that was relevant to the trial. Brahim 's
testimony would have made it clear to the Court and Jury that the reason why I co-
mingled the funds and transferred most of it to my savings account was not because I
was trying to conceal its use, but it was safer in that account. I initially transferred $3
million from my Chase bank account to my PNC bank account because this account was
linked to my United Arab Emirates bank account which contained employee payment
info such as checking account numbers, routing numbers, swift codes and Bank
addresses. It was easier to transfer the money here then from there pay the employees
than it was to have to re-enter 612 different employee account information. Moreover,
there were no rules that prohibited the transfer of PPP funds from one company account
to another. I did not proceed with the payments because the covid vaccine was not going
to be available any time soon in Ghana and paying the employees would have been a
waste of the funds since I would not be able to keep the business going even if I did so.
Kate and Brahim had access to the Kremkov and Flying Jack accounts in order to make
purchases or pay bills on behalf of the company. For this reason, I limited the amount of
funds in these accounts. Also in order to execute a wire transfer from my savings
account, it required an actual in person visit to the Bank, whereas a wire transfer from
the business account can be made in minutes with a click of a button. The main reason
was to keep the money safe and to prevent a scandal like what happened to Dodgers
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 23 of 134

Baseball player Ohtani, whose bookkeeper transferred millions from his account before
he caught on to it.
7. Failure to object to prosecutors use of events that happened when I was minor;
Although it was told to the Jury that certain portions of the case were not to be used to
adjudicate guilt, prosecutors went overboard when they started pressuring hard in an
effort to establish that I lied to the Government during my visa interview to the United
States (Exh33 Trl Trscrpt Vol4 pg1093 lines 1-11 pg1095 16-23). Mr. Finlayson knew I
was a minor then,16 years about to turn 17 years, so he should have made a strong
objection when prosecutors went overboard. Instead, he allowed them to continue to
taint me or present me as someone who was deceptive. He clearly knew that I was acting
under direction from my parents because I told him my Father obtained the passport for
me. A sixteen-year-old could not get a passport on his own. My father also accompanied
me to the visa interview at the U. S embassy in Accra Ghana.
Another point I would like to highlight in closing is the time it took for the Jury to
render a verdict. Judge Brown was addressing the Jury close to 1:30 pm right around
Lunch time and told them the downstairs break room closes at 1:30pm so they were to
stay upstairs for deliberations (Exh35 Trl Trscrpt Vol5 pg1212 Line 21-25 pg1213 1-6).
At around 2:15pm they already had a verdict. The trial proceedings ending at 2:26pm
(Exh47 Trl Trscrpt Vols pg1228 Line 25). Since It took the Jury about roughly 45
minutes to render a verdict, it is fair to conclude that they relied heavily on what they
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 24 of 134

heard from the testimonies rather than going through over 200 exhibits, reading rules
and audio tapes to fact check witness testimonies. If these testimonies are full of False
statements and Fabricated evidence, then the outcome of this entire trial is unreliable,
unfair and Unjust. United States Vs LaPage 231 F 3d 488.
Taking into consideration the totality of all the circumstances, Mr. Finlayson's actions
and inaction's were so deficient that he was not functioning as counsel guaranteed
under the 6th amendment rights. His deficiency was so prejudicial that it deprived
me the right to a fair trial whose result was reliable and violated my 5th amendment
rights. Strickland Vs Washington 466 US 688,687,1045 ct 2052, 80L ED 2d 674 (1984).
Coupled with the fabricated evidence and false testimonies presented by prosecutors,
these convictions if allowed to prevail will constitute a fundamental defect resulting in a
complete miscarriage of justice. The outcome of the trial would have been different if it
were not for these misconducts. I therefore humbly request the court to vacate the
convictions on all 10 counts of the indictment and the sentence, and any other relief
that the court may deem just and proper.
Respectfully Submitted,
Karl Lucius Delano
Pro Se
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 25 of 134

CERTIFICATE OF SERVICE
This is to certify that a copy of this motion has been hand delivered by my attorney
Sandra Michaels to Ms. Kelly Connors and Mr. Nick Evert at
600 U.S. Courthouse
75 Ted Turner Drive, S.W.
Atlanta, Georgia 30303
Dated: This 26th day of January,2026
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 26 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 40 of 66
ELECTRONIC POSTMARK • CERTIFICATION OF ELECTRONIC FILING
Taxpayer:
Carl Torjagbo
Primary SSN:
771-36-0540
Federal Return Submitted:
February 12, 2021
06:15 PM PST
Federal Return Acceptance Data:
Your return has been rejected by the IRS
The Intuit Electronic Postmark shows the date and time Intuit received your federal tax return. The Intuit
Electronic Postmark documents the filing date of your income tax return, and the electronic postmark
infonnation should be kept on file with your tax return and other tax-related documentation.
There are two important aspects of the Intuit Electronic Postmark:
1. THE INTUIT ELECTRONIC POSTMARK.
The electronic postmark shows the date and time Intuit received the federal return, and is deemed the
filing elate if the date of the electronic postmark is on or before the date prescribed for filing of the
federal individual income tax return.
TIMELY FILING:
For your federal return to be considered filed on time, your return must be postmarked on or before
midnight May 17, 2021. lntuit's electronic postmark is issued in the Pacific Time (PT) zone. If you are
not filing in the PT zone, you will need to add or subtract hours from the Intuit Electronic Postmark time
to detennine your local postmark time. For example, if you are filing in the Eastern Time (ET) zone and
you electronically file your return at 9 AM on May 17, 2021 , your Intuit electronic postmark wm indicate
May 17, 2021, 6 AM. If your federal tax return is rejected, the IRS still considers it filed on time if the
electronic postmark is on or before May 17, 2021, and a corrected return is submitted and accepted
before May 22, 2021. If your return is submitted after May 22, 2021, a new time stamp is issued to
reflect that your return was submitted after the IRS deadline and, consequently, is no longer considered
to have been filed on time.
If you request an automatic six-month extension, your return must be electronically postmarked by
midnight October 15, 2021. If your federal tax return is rejected, the IRS will still consider it filed on
time if the electronic postmark is on or before October 15, 2021, and the corrected return is submitted
and accepted by October 20, 2021.
2. THE ACCEPTANCE DATE.
Once the IRS accepts the electronically filed return, the acceptance date will be provided by the Intuit
Electronic Filing Center. This date is proof that the IRS accepted the electronically filed return.
rnNFlnFNTIAI
INT rAPI nnnn,o
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 27 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 41 of 66
ELECTRONIC POSTMARK - CERTIFICATION OF ELECTRONIC FILING
Taxpayer:
Carl Torj agbo
Primary SSN:
592-71-6010
Fede,., Return Submitted:
February 06, 2021
06:05 PM PST
Federal Return Acceptance Date:
Your return has been rejected by the IRS
The Intuit Electronic Postmark shows the date and time Intuit received your federal tax return. The Intuit
Eledronic Postmark documents the filing date of your income tax return, and the electronic postmark
information should be kept on file with your tax return and other tax-related documentation.
There are two important aspects of the Intuit Eledronic Postmark:
1. THE INTUIT ELECTRONIC POSTMARK.
The eiedronic postmark shows the date and time Intuit received the federal return, and is deemed the
filing date if the date of the electronic postmark is on or before the date prescribed for filing of the
federal individual income tax return.
TIMELY FILING:
For your federal return to be considered filed on time, your return must be postmarked on or before
midnight May 17, 2021 . lntuit's electronic postmark is issued in the Pacific Time (PT) zone. If you are
not filing in the PT zone, you will need to add or subtrad hours from the Intuit Eledronic Postmark time
to detennine your local postmark time. For example, if you are filing in the Eastern Time (ET) zone and
you electronically file your return at 9 AM on May 17, 2021, your Intuit electronic postmark will indicate
May 17, 2021, 6 AM. If your federal tax return is rejected, the IRS still considers it filed on time if the
electronic postmark is on or before May 17, 2021, and a correded return is submitted and accepted
before May 22, 2021. If your return is submitted after May 22, 2021, a new time stamp is issued to
reflect that your return was submitted after the IRS deadline and, consequently, is no longer considered
to have been filed on time.
If you request an automatic six-month extension, your return must be electronically postmarked by
midnight October 15, 2021. If your federal tax retum is rejected, the IRS will still consider it filed on
time if the electronic postmark is on or before Odober 15, 2021, and the corrected return is submitted
and accepted by Odober 20, 2021.
2. THE ACCEPTANCE DATE.
Once the IRS accepts the electronically filed retum, the acceptance date will be provided by the Intuit
Eledronic Filing Center. This date is proof that the IRS accepted the electronically filed return.
CONFIDENTIAL
INT CARL 000175
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 28 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 20 of 6~SfP1'\e, 0#1
t ••
TRDPG 771-36-054·0 30202012
MIA ACCESS CODE:QA PAGE:001 OF 004
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-04-08
NAME-CNTRL:TORJ TXPYR:P FILING STATUS:l REFUND:Y BAL DUE:
INPUT-SOURCE:MEFILE
FORM:1040
OCCURRENCE: 1 CURRENT-STATUS:MF POSTED
LINE#
ENTITY/ATTRIBUTE
VALUE
CHANGED VALUE
INDIVIDUAL NAME
FILER SSN
771-36-0540
TAXPAYER CODE
p
T NAME CONTROL NAME
TORJ
INDIVIDUAL NAME
FIRST NAME
CARL
LAST NAME
TORJAGBO
ADDRESS
STREET ADDRESS
3081 LEATHERLEAF TRL
CITY NAME
DOUGLASVILLE
STATE CODE
GA
ZIP CODE
30135
ZIP PLUS FOUR CODE
8930
TRDPG 771- 36-0540 30202012
MIA ACCESS CODE:QA PAGE:002 OF 004
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-04-08
NAME-CNTRL:TORJ TXPYR:P FILING STATUS:l REFUND:Y BAL DUE:
INPUT-SOURCE:MEFILE
FORM:1040
OCCURRENCE: l CURRENT-STATUS:MF POSTED
LINE#
ENTITY/ATTRIBUTE
VALUE
CHANGED VALUE
1
8
9
11
23
24
25D
30
32
33
INDIVIDUAL RETURN
WAGES AMOUNT
ADDITIONAL INCOME AMOUNT
TOTAL INCOME AMOUNT
ADJUSTED GROSS INCOME AMOUNT
TOTAL OTHER TAX AMOUNT
TOTAL TAX AMOUNT
WITHHLD FEDERL INCM TAX AMOUNT
RECOVERY REBATE CR AMOUNT
REFUNDABLE CREDIT AMOUNT
TOTAL PAYMENT AMOUNT
T BAL DUE OR REFUND AMOUNT
DIRECT DEPOSIT
$9,199,411.00
$9,999,360.00-
$799,949.00-
$799,949.00-
$88,194.00
$88,194.00
$3,459,835.00
$1,800.00
$1,800.00
$3,461,635.00
$3,373,441.00-
35B
ROUTING TRANSIT NUMBER
054000030
35D
DIRECT DEPOSIT ACCOUNT NUMBER
5571329849
05/27/2022
Page 2 of 17
.oo
3,459,835.00
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 29 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 20 of 6lV'if:ij~•~ ft@sl
t
•
•
TRDPG 771-36-054·0 30202012
AAIA ACCESS CODE:QA PAGE:001 OF 004
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-04-08
NAME-CNTRL:TORJ TXPYR:P FILING STATUS:l REFUND:Y BAL DUE:
INPUT-SOURCE:MEFILE
FORM:1040
OCCURRENCE: 1 CURRENT-STATUS:MF POSTED
LINE#
ENTITY/ATTRIBUTE
VALUE
CHANGED VALUE
INDIVIDUAL NAME
FILER SSN
771-36-0540
TAXPAYER CODE
p
T NAME CONTROL NAME
TORJ
INDIVIDUAL NAME
FIRST NAME
CARL
LAST NAME
TORJAGBO
ADDRESS
STREET ADDRESS
3081 LEATHERLEAF TRL
CITY NAME
DOUGLASVILLE
STATE CODE
GA
ZIP CODE
30135
ZIP PLUS FOUR CODE
8930
TRDPG 771-36-0540 30202012
AAIA ACCESS CODE:QA PAGE:002 OF 004
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-04-08
NAME-CNTRL:TORJ TXPYR:P FILING STATUS:1 REFUND:Y BAL DUE:
INPUT-SOURCE:MEFILE
FORM:1040
OCCURRENCE: 1 CURRENT-STATUS:MF POSTED
LINE#
ENTITY/ATTRIBUTE
VALUE
CHANGED VALUE
INDIVIDUAL RETURN
1
WAGES AMOUNT
8
ADDITIONAL INCOME AMOUNT
9
TOTAL INCOME AMOUNT
11
ADJUSTED GROSS INCOME AMOUNT
23
TOTAL OTHER TAX AMOUNT
24
TOTAL TAX AMOUNT
25D
WITHHLD FEDERL INCM TAX AMOUNT
30
RECOVERY REBATE CR AMOUNT
32
REFUNDABLE CREDIT AMOUNT
33
TOTAL PAYMENT AMOUNT
T BAL DUE OR REFUND AMOUNT
DIRECT DEPOSIT
$9,199,411.00
$9,999,360. 00-
$799,949.00-
$799,949.00-
$88,194.00
$88,194.00
$3,459,835.00
$1,800.00
$1,800.00
$3,461,635.00
$3,373,441.00-
35B
ROUTING TRANSIT NUMBER
054000030
35D
DIRECT DEPOSIT ACCOUNT NUMBER
5571329849
05/27/2022
Page 2 of 17
.oo
3,459,835.00
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 30 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 21 of
TRDPG 771-36-0540 30202012
AAIA ACCESS CODE:QA PAGE:003 OF 004
2022-05-27 10:01:27 FORM-F,.n.MILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-04-08
NAME-CNTRL:TORJ TXPYR:P FILING STATUS: l REFUND:Y BAL DUE:
INPUT-SOURCE:MEFILE
F0~:1040
OCCURRENCE: 1 CURRENT-STATUS:MF POSTED
LINE#
ENTITY/ATTRIBUTE
VALUE
CHANGED VALUE
Sl 5
$2 8
INDIVIDUAL RETURN
SUPPLEMNTL INCH OR LOSS AMOUNT
F8959 8960 OTHER TAX AMOUNT
STANDARD DEDUCTION AMOUNT
COMPUTED TOTAL TAX AMOONT
TOTAL TAX LIABILITY AMOUNT
TOTAL TAX ASSESSMENT AMOUNT
ADJSTD TAX PER TXPYR AMOON'.l'
COMPUTED BAL DUE REFUND AMOUNT
INTEREST PENALTY DATE
INTRST RDCTN OVRPYMNT AMOUNT
MEF GENERATED
IP ADDRESS
EF!N NUMBER
SOFTWARE ID NOMBER
PRIMARY IPPIN INDICATOR
$9,999,360.00-
$88,194.00
$12,400.00
$88,194.00
$88,194.00
$88,194 . 00
$88,194.00
$3, 371,641.00-
2021-04-15
$3,371,641.00-
73.106.108 . 92
440894
20011235
y
TRDPG 771-36-0540 30202012
AAIA ACCESS CODE:QA PAGE:004 OF 004
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-04-08
NAME-CNTRL:TORJ TXPYR:P FILING STATUS:l REFUND:Y BAL DUE:
INPUT-SOURCE:MEFILE
FORM: 10 4 0
OCCURRENCE: l CURRENT-STATUS: MF POSTED
LINE#
ENTITY/ATTRIBUTE
VALUE
CHANGED VALUE
SECONDARY IPPIN INDICATOR
BANK PRODUCT DlSBURSMNT CODE
BANK ROUTING NUMBER
BANK ACCOUNT NUMBER
05/27/2022
y
2
054000030
5571329849
Page 3 of 17
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 31 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 22 of 6
TRDPG 771-36-0540 30202012
MIB ACCESS COOE:QA PAGE:001 OF 001
2022-05-27 10: 01: 27 FORM-FAMILY: 1040
TAXYR: 2020
TRDB-DT-RCVD:2021-04-08
NAME-CNTRL:TORJ TXPYR:P FILlN(; STATUS:l REFUN,D:Y BAL DUE:
INPUT-SOURCE:MEFILE
f'ORM:SCH-E
OCCURRENCE: 1 CURRENT-STAT-OS:MF POSTED
LINE f
ENTITY/ATTRIBUTE
VALUE
CHANGED VALUE
PRTNRSHP AND CORP INCM OR LOSS:
II29BI TOTAL NONPASSIVE LOSS AMOUNT
I I 31
TOTAL LOSS AMOUNT
TOTAL INCOME OR LOSS AMOUNT
$9,999,360.00
$9,999,360.00
$9,999,360.00-
TRDPG 771-36-0540 30202012
AAlC ACCESS CODE~QA PAGE:001 OF 001
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR : 2020
TRDB-DT-RCVD:2021- 04-08
NAME-CNTRL: TORJ TXPY.R: P FILING STATUS: 1 RE FOND: Y BAL DUE:
INPUT-SOURCE: ME FILE
FORM:W-2
OCCURRENCE: 1 CURRENT-STATUS:MF POSTED
l,lNE ii
ENTITY /ATTRIBUTE
VALUE
CHANGED VALUE
HEF GENERATED
W2 EMPLOYER ADDRESS
W2 WAGES AMOUNT
W2 WITHHOLDING AMOUNT
W2 :EMPLOYER EIN
05/27/ 2022
us 30135
$9,199,411.00
$3,371,641.00
83-1821377
Page 4 of 17
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 32 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 23 of
4
.,J
l
TRDPG 771-36-0540 30202012
AAID ACCESS CODE:QA PAGE:001 OF 001
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-04~08
NAME-CNTRL: TCiRJ TXPYR: P Fl LI NG STATUS: 1 REFUND: Y BAL DUE:
INPUT-SOURCE: MEFILE
FORM:8959
OCCURRENCE: 1 CURRENT-STATUS:MF POSTED
LINE#
ENTITY/ATTRIBUTE
VALUE
CHANGED VALUE
I1
n
IV18
Vl9
V24
ADDITIONAL MEDICARE TAX
MEDICARE WAGES AMOUNT
ADDNL MEDI TAX WAGES AMOUNT
TOTAL ADD MEDICARE TAX AMOUNT
MEDICARE TAX WITHHELD AMOUNT
REGULAR MEDI 'rX WITHHLD .AMOUNT
AD MDCR TX MDCR WGS AMOUNT
TOT ADD MEDTX WITHHLD AMOUNT
$9,999,360.00
$88,194.00
$88,194.00
$233,185.00
$14 4 , 9 90 . 72
$88,194.28
$88,194.00
TRDPG 771-36-0540 30202012
AAIE ACCESS CODE:QA PAGE~OOl OF 001
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-04-08
NAME-CNTRL:TORJ TXPYR:P FILING STATUS:l REFUND:Y BAL DUE:
INPUT-SOURCE:MEFILE
FORM:CHANG-HIST OCCURRENCE: 1 CURRENT-STATUS:MF POSTED
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19
2021-04-08
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19 1040
19 1040
05/27/2022
#
LN RF SEQ ATTRIBUTE NAME
01 32
REFUNDABLE_CREDIT_AMOUNT
01 3J
TOTAL_PAYMENT_AMOUNT
Page 5 of 17
DATA
.00
3,459,835.00
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 33 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
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Page 24 of 6
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AAIF ACCESS CODE:QA PAGE:002 OF 002
2022-05-27 10:01:27 FORM-FAMILY:1040
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05/27/2022
Page 6 of 17
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ABIB ACCESS CODE:QA PAGE:001 OF ,001
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05/27/2022
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ABID ACCESS CODE:QA PAGE:001 OF 001
2022-05-27 10:01:27 FORM-FAM!LY:1040
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TROPG 771-36-0540 30202012
ACI}I. ACCESS CODE:QA PAGE:001 OF 001
2022-05-27 10: 01 :27 FORM-FAMILY: 1040
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TRDB-OT-RCVD:20'21-02-12
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ACIB ACCESS CODE:QA PAGE:001 OF 001
2022-05-27 10:01:27 FORM-FAMILY:1040
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05/27/ 2022
1
FW2-505-0l
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ACIC ACCESS CODE:OA PAGE:001 OF 001
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TAXYR:2020
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2021-02-12
440893202103704ANJ07
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12 771360540 30 202012
'rRDPG 771-36-0540 30202012
ACID ACCESS CODE:QA PAGE:001 OF 001
2022-05-27 10: 01: 27 FORM-FAMILY: 1040
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Page 12 of 17
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TRDPG 771 - 36 - 0540 30202012
2022 - 05 - 27 10 : 01 : 27 FORM-FAMILY : 10 40
ADID ACCESS CODE : AD PAGE 001 OF 001
TAXYR : 2020
TRDB - DT- RCVD : 2021 -0 2-1 3
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Page 13 o f 17
! W1-2 - Page 22 of 26,
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TRDPG 771 - 36 - 0540 30202012
2022 - 05 - 27 10 : 01:27 FORM-FAMILY : 1040
ADIB ACCESS CODE : QA PAGE : 001 OF 001
TAXYR : 2020
TRDB - DT- RCVD : 2021 - 02 - 13
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TRDPG 771 - 36 - 0540 30202012
2022 - 05-27 10:01 : 27 FORM- FAMILY : 1040
5- 01
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05 / 27 /2 022
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! W1-2 - Page 23 of 26
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TRDPG 771 - 36 - 0540 30202012
2022-05-27 10 : 01 : 27 FORM-FAMILY : 1040
ADID ACCESS CODE : QA PAGE : 001 OF 001
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Case 1:22-cr-00171-MLB-RDC
Document 240
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ADID ACCESS CODE:QA PAGE:001 OF 001
2022-05-27 10:01:27 FORM-FAMILY:1040
TAXYR:2020
TRDB-DT-RCVD:2021-02-13
NAME-CNTRL:1360 TXPYR:P FILING STATUS:
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TRDPG 771-36-0540 30202012
AEID ACCESS CODE:AE PAGE 001 OF 001
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TAXYR:2020
TRDB-DT-RCVD:2021-02-1 2
NAME-CNTRL:1360 TXPYR:P FILING STATUS:
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1
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1
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TAXYR:2020
TRDB- OT- RCVD:2 021-02-12
NAME-CNTRL:1360 TXPYR:P FILING STATUS:
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AEIB ACCESS CODE:QA PAGE:001 OF 001
2022-05-27 10:01:27 FORM-FAMILY:1040
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TRDB-DT-RCV0:2021-02-12
NAME-CNTRL:1360 TXPYR:P FILING STATUS:
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05/27/2022
1
5-01
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Case 1:22-cr-00171-MLB-RDC
Document 240
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TAXYR:2020
TRDB-DT-RCVD:2021-02-12
NAME-CNTRL:1360 TXPYR:P FILING STATUS:
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2021-02-12
4408932021 037 04ANJ07
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TAX FILING
TRANS
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PER
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12 771360540 30 202012
TRDPG 771-36-0540 30202012
AEID ACCESS CODE:QA PAGE:001 OF 001
2022-05-27 10:01:27 FORM-FAMILY:1040
TAX:YR:2020
TRDB-DT-RCVD:2021-02-12
NAME-CNTRL:1360 TXPYR:P F.ILING STATUS:
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05/27/2022
CODE 0
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Page 17 of 17
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Case 1:22-cr-00171-MLB-RDC
Document 240
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Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 45 of 134

•
Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Flier Name CARL<TORJAGBO
ary Name Cont
Phone (470) 889-9183
Flier U.S. Address 3081 Leatherleaf Tri
Douglasville, GA 301358930
Prima!'.Y Date of Birth 1979-09-10
Primary Signature •--•••
Primary Signature Date 2021-02-13
Primary Prior Year AGI
274
PIN
On-Une
354581
Tax Period ~In Date 2020-01-01
Tax Period End Date 2020-12-31
Software ID 20011235
Primary PIN Entered By Taxpayer
Tax Year 2020
Binary Attachment Count O
Routing Transit Number 054000030
Depositor Account Number 5571329849
Email Address torjagboc@gmail.com
IP Address 73.106.108.92
Device IO 9844F81E1408F6ECB932137D33BED7CFOCF518A3
Jurat Disclosure Code Online Self Select PIN
Your browser cannot support IFRAME.
,. -
Exh5
Page 43 of 66
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 46 of 134

' •··
Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 34 of 66
SSfDERID
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Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 47 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 35 of 66
APPLICATION
RECElYEDTIMESTAMP
POSfMARKnMESTAMP
LEGAL.NAME
TURBOTAX-ONUNE
Feb 6, 20216:05:57 PM
Feb 6, 20216:05:57 PM
Carl Torjagba
JURBOTAX-ONUNE
Feb 6, 2021 n06:01 PM
Feb
202111:06:01 PM
Carl Terjagbo
TURBOT~-ONLINE
Feb 6, 202111:06:01 PM
f eb 6, 202111:06:01 PM
Carl Tarjagbo
TURBOTAX-ONUNE
Feb 12, 20216:15:26 PM
Feb 12, 20216:15:26 PM
Carl Tarjagbo
TURBOT AX-ONLINE
Feb 12, 2021 6:15:26 PM
Feb 12, 20216:15:26 PM
Carl Torjagbo
TUR.BOTAX-ONUNE
Feb 12, 20216:37:59 PM
Feb l2. 20216:31:59 PM
Cart Torjagbo
TURBOTAX-ONUNE
Feb 13, 2021 8:42:10 AM
Feb 13, 20218;42:10 AM
Carl Torjagbo
TURBOTAX--ONUNE
feb 13, 2021 t42:10 AM
Feb 13, 20218:42:10 AM
Cart Torjagbo
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 48 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 36 of 66
TAXPAYERADDRESS
TAXPAY£RZIP
TAXPAYERPffONEHUMBEJI
TAXPAYEROOB
2220 WESTCR~ lN APT E71. tlOOSTON, TX
77-027
4708ffl183
Sep 8, 1975 12:00:00 .AM
3081 UAlllERUAF TRL, DOUGLASVILLE, GA
30195
4708899183
Sep 10, 1979 mOQ:OO AM
3081 LEATHERUAF lRL. DotlGLASYII.U, GA
30135
4708899183
Sep 10, 197912:(HkOO AM
3081 UATIDlEAF TRl. OOOGlASVII.LE. GA
30135
4708899183
Sep 10, 19'19 12:0lkDO AM
3081 LEATHERLEAF lRL, DOUGLASVlll.£. 8A
30135
4708899183
Sep 10, m9 lttl0:00 AM
2220 WESTCRttK LN APT E7l, HOUSTON, TX
n-021
4708899183
Sep 8, 1975 12:00:110 AM
3081 :LEATHERLEAF TRL, OOUGI.ASVIU.E, ,GA
30135
4708899183
Sep 10, 1979 12;1111:00 AM
3081 LEATHERLEAF TRL. DOUGLASVILLE, GA
30135
4708899183
Sep 10, 1979 l2:0lQOi AM
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 49 of 134

• : •
Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 37 of 66
SPDUSESSN
SPOUSEUSTNAME
SPOUSEOOB
o,AllADORESS
CARl.DB.AN0310UllOOK£0M
TDRJA68PC§G)4AILCOM
TORJAGBOCIGMAILCOM
T1llUAGBOCIGMAILt(l4
TORJA680CIGNAILCOM
CARLOruN03(!)00TLOOlttOM
TORJAGBDCIGMAILci>M
TORJAGBOCllGMAILCOM
IPADDRESS
73.106.108.92
73.10UOU2
73,106.108.92
73.106.108,9,2
73.106.108.92
13.106.1002
71106.108.-92
73.106.108.92
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 50 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
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M4CHlNlJD
UnknewnVISitortctUnknownDeviceld
UnknewnVfsiJortctUn~.wnDeviceld
UnknownVisitl)ffd:Un'91,w11Deviceld
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llnknownVisit1rld:1Jnkntwnbevicekl
Unkn,w~YisiteritUnkhovttiOevlceM!
UnknowiMsitorl~knownOeviceld
ORDER.NUMBER
EFEC:tn592ffi84
EF£Cm59873041
BANKACCOUNJ
741438755
S57132981t9
5571329849
741438755
~571329~9
ROUTINGNUMBER
!PA'YMEN'rA:MOUNl
061092387
0540001)30
0.0
054000030
0.0
061092387
D5.,0001130
0.-0
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 51 of 134

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Document 240
Filed 09/08/25
Page 39 of 66
REFUNDAMOUNT
3015513.0
3373441.0
0.0
3373441.0
0.0
3015573,0
3373441.0
0.0
EflN XPATH
/efil,:Retum/efile:ReturnData/efile:IRSW2[1]/efile:E,nployer£1N
/efile:Return/efile:ReturnData/efildRSW2(1)/efile:EmpltyetfJN
(1000
/efile:Return/efila:ReturnData/efile:IRSW2(1]/efile:&nployerfJN
0000
ERRDRCDO£
fW2-5'05-tn
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1REJ001
!fW2-505-01
REJODl
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 52 of 134

.. • -"" ~ase 1:22-cr-00171-MLB-RDC
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Page 44 of 66
20811
•
Rules and Regulations
Thie~ of th, FEDERAL REGISTER
oonidts ~
~
having
ral
~
tind legal·-.ct, moet of=
.,. lal!)!lld ID and. codified 1h h Codli of
Fideral ~.
which la pubWied imer
50 ._ purtuant lo ,._ U.8.C. 1510.
The Codit"' Ftderal ~
Is sold by
1hil Q.tpel'lnllN ldent of Ooctmen111.
SIP.LL 8USINESS ~l*-INISTil~TION
13 CFR Part 120
[Doclill No.~6)
Afftn41--AH34
9m1,..._ LNn Proltw'JI TMnporery
Cbmgea; ~
·Protedlon
PiogfMI
AGl!HCY: U.S. Small Businesa
Administration.
ACTION: Interim final rule.
~
Thia intarim&al rule
anno:uncea the implementation of
Mctf:oos 1102 and 1106 of the
Coronavirwl Aid, Relief, and Economic
Security~ {CARES Act or the Act).
~
110.2 of the Act temJl()rarily
111dd, a D@W Jll'Oduct. titled the
"Payclleck Protection Program/' to the
U.S. Small Buameaa Adminiatration's
(SBA'a) 7(a) Loan Prognun. Section 1106
of the Act provides for furgiVBDeaa of up
to the full principal amount of
qualifying loans parmtBtid Under the
Paycheck Protection Program. The
Paycheck Protection Program and loan
forsivenea are intended to provide
aoonomic relief to IUlall busin""9
nationwide adversely impa,.ted under
the Coron.avirv,s Diseue 201.9 (COVID-
19) Em:9119Dcy Declaration {OOVID-19
Emezsency Declantioo) iNued by
Pfeeldent Tromp on ~h 13, 2020.
Thia interim final rule OU,l&es the key
provlslona of SBA's implementation of
~ons 1102 and 1106 of the Aot in
formal guidance and requests public
comment.
DATES:
B/ffJctiw date: This interim final rule
le effective AP.Jil 15, 2020.
Applicability dat.e: Thia interim final
n:ile appliei to applications submitted
under the Paycheck Protection Program
throqgh June 30, 2020, or until funds
made available for th.is purpose am
exha~.
Comm,mt Data: Comment.a muat be
mceived on or befont May 15, 2020.
AODRESSES.: You may .submit comments.
identified by numba:r SBA-202o--0015
through the Fedmel eRulllD'lakillg Portal:
http://www.regulatiom,gov. Follow the
instructions for aubmittiug comments.
SBA will p(>l1: all oo~ts on
www.JYlgUlations.pv. If you wish to
submit confidential busineaa
information (CBI} u defined in the User
Notke at www.regu.latiom.gov, please
send,an email to ppp-ifr@sba.gov.
High.light tbs information that you
consider to be CBI and explain why you
believe SBA thould hold this
information, as confidential. SBA will
n,view the information and make the
final d~ti()Il whether it will
publish the information.
FORlUmER~TiONCDNTACT:Call
Center Repreaentstiva at 83.s--572-0502,
or the local SBA Fivld Office; the liet of
offices can be found at https:I I
www.M>a.gavltools/local-oni8tonce/
dilllrlcto/ficff.
SWPl.EMENT,4RY INFPRMATIDN:
I. Bacqround lnfarmatioo
On .March 13, 2020, Pmtident Trump
declaNKl tbs qoing Camnavirua
Dise!ue 2019 {COVlB--19) pandemic of
sufflclent sev.erlty and magrutude to
warrant an emerpncy declaration for all
statea, territories. and the District of
Columbia. With tbs COVlB--19
emeJ18Dcy. many small bUJin8Sl88
nationwide are experienclng economic
hardihlp as a dl.ruct result of the
Federal, State, and local public health
m411Ulures that are l>eiJls 'taku to
minlm,iq the publlc'• exposure to the
virus. The,e m'&11111U'8s, some of which
are. gowmment-mandated, are being
implemented nationwide and include
the cloaw:ea of restAlµranlJ, hara, and
gym.. ID additJOJ.i, hued on the advice
of public hN.lth offlciala, other
meuuru, such aa Jr.eepq a .re
distance from other• or even stay-at-
home ord8l8, 81'11 beina implemented.
resulting in a dramatic dec:1'911$8 in
economic activity as the public avoids
malla, retail St0l'91, and other
businetees.
On March 27. 2020, the Pnisident
signed 1he Coronevitµa Aid, Relief, and
Economic Security Act (the CARES Act
or the Act) (Pub. L. 116-136) to provide
emergency ueiatance and health care
responee for individuals, famillea, and
buaineuea .trected by the oo:ronavirus
pandemic. The Smalf Buaineo
Adminlstmtion {SBA) received funding
PaQe 10
Fed•.la-,ilter
Vol. 85, No. 73
Wednaday, April 15, ZOZO
and authority through the Act to modify
ex:iatiDg loan program, and esttblish ,a
new lnan program to ..-tit mwl
bu.slneeaea nationwide advvrsely
impacted by the COVID-19 81Jl8l'j8DC)'.
Section 1102 of the .Act temporarily
pannits SBA to guarantee 100 paroent of
7(a) loans under a new program UOed
the "Paycheck ~action Program."
Section .1106 of the Act provides for
for:giveneta of up to the full principal
&.mO\.Ult of qualifym& loans ,81llll1SDl-1
;under the ~aychoc:k iProtectl!Jll Progm:n.
A more deWled diactl85ion of sections
110~ and 1.106 of the Aet is found in
.section ID below.
n. Comme,n._ and lmmedlabl Efl'ec:tiq
Date
The intent of the Act ls that SBA
provide rellefto America's small
bt111ine11e11 expeditiously. Tha intent,
along with the dramatic decrease ln
economic activity'D.lltionwide, providei
good cause for SBA to dispense with the
3o-day delayed effective date provided
in the Administrative Procedure Act.
Specifically, ama1l buainM888 need to be
informed on how to apply for a loan and
the terms of the loen under section 1102
of the Act u aoon u pouible beoa1198
the Jut day to app}y for and N1ceive a
loan 1a June ,o, 2020. The.immediate
effectiTIJ date of th.ill interim final rule
will benefit amall bu.smeuea 10 that
they .c1U1 immediataly apply for the loan
with a full Undentandlng ofloan 'terms
and conditiom. This interim.final fUle
ill eff8ctive without advance notice and
public comment because section 1114 of
the Act authorizes SBA to issue
regulations to implement Title 1 of tbs
Act without regard to notice
requirements. This rule la bein,g issued
to allow for immediate implementation
of thia Pt'Q8l'IUl1• Although th.is interim
1lnal role la ·effectlve immediately,
1:oimliettta ate eolicited fmm interested
members of the public on all aspects of
the interim. final rule, including section
m below. These comm.enta must be
Jubmitted ,on or before May 15, 2020.
The SBA will consider these commenhl
and tbs need for making any revisions
All a reiult of'theae comments.
DL T411qporuy New BUAOtu Loan
Program: Pa,ycheck Protection Program
Overview
The CARES Act was enacted to
provide immediat& IIB8i&tmce to
individuals. run.mes, and businesses
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C
•
'
Case 1:22-cr-00171-MLB-RDC
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.
t
20812
Federal Regi,ter/Vol. 85 .• No. 73/Wednesday, April 15, 202O/Rulea and Regulations
affected by the COVID-19 emargmcy.
Among the proviltona contained 1n. the
CAJmS Act .lint ptovaiOD.t authorizing
SB~ to tempol'!liily guilrlUitee loana
501(c)(.3) ofthe Internal Revenue Code
(!RC), a tax-exempt veterms
org1udztUon dtllQ'.ibed in Metion
501(c)(19) of the IRC, Tribal busin888
concern deecri,bed in aectioo 31(b)(2){C}
of the Small Busineu Act, or any other
bu4ineBS;end
undat a new .7(a} loan propam. titled th.e
"Paychecl: Protection ~am." Loans
guaranteed
. . under the. Pc;
.•. :fcheck
J>rot.«:tion ~
.~J will be 100
pen::ent guatariteed bv SBA, and the full .
priridpal amount of the loans may
'
®allfy for loan fmtivenees. The
following ontlinea the key {'i'Ovw.ona of
the PPP.
1, General
SBA ia authorir.ed. to guanmtee l08D8
under the PPP tbroµsb. June 30, 2020.
CongJNI authorized a program lsvel of
$349,000,000,000 to provide guaranteed
loana under thiu1ew ,(a} .prognun. The
intent of the Act is that SBA provide
relief to Amarlca'• sl:Wlil bullinenes
axpeditioualy, which ui expreued in the
Act by giving all lenders delegated
authority and stnJernJfning tw,
requirement. of the regular 7{a) loan
program. For example, !or loans made
under the PPP, SBA will not require the
lendai'I to comply with section 120.1so
"Wluat are SBA'e lending criteria?." SBA
will ellow lend.en to rely oo
cartiflcatiOJ11 of the borrower in order to
detamune eligibility of the borrower
and uae of lOtlJl proceeda and to rely on
1pecified documeilta provided by the
borrower to deti:irm.ine qwill:fying loan
BlllQUDt and aliglbt.Uty for loan
futaiveneu, Landerunuat comply with
the applicable lender obliptiou ,et
forth in th.ts interim final rule, but will
be held harmleu for borrowm' failure
to comply "1th program criteria:
remedlee for borrower violatlona ot
fraud are eepara
. tely. adCllllll.98d
.
in this
interim tmal rule. The p .
niquiremeots of the PPP ~fied in
thi.a rule temporarily aupeti!ede any
coofll.ctina Loan :PrQgram Requirement
(aa defioeo in 13 CFR 120.lOf,
2. What do bonowen need to know •and
doT
•
a. Am I ellgibleT
You are~ble for a PPP loan if you
bave 59() or I.war emJ>loyees wbt)fe
,principal plaatofn,idenceidn th4'
United State,, or ar& a buainltSS that
OJ)&t'llblt in a c:fflain induetry end meet
the applicable SBA. employ...:bued sir.e
etaodardt tor that indu.my, and:
i. Youm:
A. A small buslnau concern as
defined in 1ectJoo 3 of the Small
BWlinN8 Act (1.5 U.S.C. 632), .and
l!Ubject to SBA's affiliation ruJ91 under
13 CFR 121.301[0 unless specifically
waived in the Act; or
B. A tax..exempt nonprofit
organization de,cn'bed in 18ctiOD
'~ ' •
.~
•··
j
documentation, auch as ·bank records,
1uflieient to demonstrate the qualifying
payroll amount
SBA intends to promptly i&IU8
additional guidance with regard to the
applicability ofaftiliation rules •t 13
CFR 121.103 and 121.301 to PPP loans.
b. Could I be ineligible even if I meet the
eligibility raquiremente in (a) above?
You are ineligible fur a PPP loan if, for
example:
i. You are 8I!88800 in any activity that
fa illepl under Federal, state, or local
law;
ii. You 1tf6 a hoUl8hold employer
(individuals who employ household
employees IIUCh u nannies or
houeebepers):
iii. An QWJler of ZO percent or m.ore
of the equity of the applicant is
Jncarcarated, on probation, on parole;
presently subject to an indictment.
criminal infonnatioo, ~roeo\, ot
other mean. by which formal criminal
ch8.Ipll a,e brought in any jurisdiction;
or hu been convicted of a felony within
the last five years; or
iv. You, or any bwnness owned or
controlled by you or any of your
ownm, has ever obtiine.d a ditect 01
guBX'811tead loan from SBA or any other
Federal agency that ill cunently
delinquent or bu defaulted within the
last seven years and caused a '1P18 to the
government.
The Administrator, in comultation
with the Secretary of the Treuu:ry (the
Secretary), debmoined that houaehold
employers ate ineligible because they
are not busin81118s. 13 CFR 120.100.
Paoe 11
c. How do I determine if I am loeligl:ble?
Bu.tnaues that u, not eUgible for
PW loana m tdenttfi'e.d in 13 CFR
120.110 and deaerlbed further. in SB.A's
Standard Operating Procedure (SOP) 50
10, Subpart B, Chapter 2, except that
nonprofit organizations authorlmd
undv the Act are eligible. (SOP :SD 10
can be round at https:llwww.sba.gov/
documentlsop-50-10-5-lender-
dBVelopment-company-Ioan-prosmma.)
d. I have determined that I am eligible.
How much can I borrow?
Under the PPP, the .maxim.um loan
·amount is the leaser of $1 o million or
an amount that you will calculate using
a payroll•bued formula specified in the
Act, as explained below.
e. How do I calculate the maximum
·amount 1 can bOJTOw?
The following methodology, which is
one of the methodologies contained in
the Act, will be moat UHful for many
applicantll.
f. Step 1: Aggregate payro costs
(defiDed in detail below inf.) from the
last twelve months for employees wb01e
principal place ofreetdence ill the
United Stati:11.
U. Step 2: Subtract any compensation
paid to an employee in excess of an
annual salary of $100,000 and/or any
amounts paid to an independent
contractor or sole proprietor in excess of
Sl00,000 per year.
ill. Step 3: Calculate average monthly
payroll co,ta (divide the amount from
Step 2 by 12),
iv. Step 4: Multiply the average
monthly payroll coat.a from Step 3 by
2.5.
v. Step 5: Add the outstanding
amo1U>t of an Econ.Qmfc Infury Disaater
Loan (EIDL) made between January .31,
2020 and April 3, 2020, 1881 the amount
of any "advance" under an EIDL
COVID-19 loan (became it does not
have to be repaid).
The examples below illustrate this
methodology.
1. Example 1----No employees make more
than $100,000
Annual payroll: $120,000
Average monthly payroll: $10,000
Multiply by 2.5 = $25,000
Maximum loan amount is $25,000
ii. Example 2-&me employeee make
mote than $100,000
Annual payroll: Sl,500,000
Subtract oompenaation amounts in
ex<:eaa .of an annual salary of
$100,000: $1,200,000
AVlltli8& monthly qualifying payroll:
,$100,000
Multiply by 2.s = s2so,ooo
Maidmim loan amount is $250,000
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.Fedmal hgi8ter/Vol. 85, No. 73/Wedneeday, April 15, 2020/Rulea and RegulatiollB
20813
ill. Example 3-No employees make
more than $100,000, outat.mding
EIDL loan of $10,000.
Annual payJ;Oll: $120,000
Avei
.· mOI1thly payroll: $10,000
Mul
. bv 2,5 • $25,000
Add
L loan of $10,000 .. S3!1,000
Muimum loan amount ia $35,000
iv. Example 4-Some employees make
more tban $100,000, outstanding
EIDL lo.In of $10,000
Annual payroll: $1,500,000
Subtract compensation amountt in
excau of an annual ealary of
$100,000: $1,200,000
A~ monthly qualifying payroll:
$100,000
Multiply by 2.5 := $Zll0,000
Add BIOL loan of $10,000 • $260,000
Maximum loan amount ia $260,000
f. What qualifies as "payroll coa.ta?"
Payroll C011ta consist of compensation
to amployeN (whose principal place of
residence ii the United States) in the
form of 18.lazy, wagee, CODUJllMiona, or
similar compensation; cub tips or the
equivalent (hued on employer record.
of put tips Qr, in tbe abaence of aucb
record,, a reeeonable, good-faith
employer •thnate of tuch tips):
payment for vacation, parental. family,
medical, or lick leave; allowance for
separation or dismisaal; payment for the
proviaion of employ" benefits
c:on,lating of group health care coverage,
includins m,unnce premiums, and
19tirement; payment of et.ate and local
tax• u18118d oli compemation of
employee.; and for an independent
contractor or aole proprietor, w-agee,
commiAiom, income, or net eam.inga
from self-eiployment, or similar
cmnpenaation.
8· Ia there anything that is axpl'811ly
excluded fn)ln tb.e de$dtion of payroll
coat.,'?
,
,
Yea. The Act expressly excludes the
following:
•
J. A:o.y coµipenaation of an employee
wb01e principal place of residenc.e ia
outaide of the United Statea;
il. The compeuation of an individual
employee in exceu of an annual salary
of $100,000, prorated_asnec;esaary,
ru. Federal &PJployment taxes
impoeed or withheld between Febnwy
15, 2020 and June 30, 2020, including
the em.ployee'• and employer'• share of
FICA (Federal ina!lHDce ContributiUDa
Act) and Railroad Retirement Act taxaa,
and income taxea i:equired to be
withheld fiom wployeea; and
iv. Quali1ied aiclc and Camily leave
wages for which a credit ia allowed
under aectiona 7001 and 7003 of tha
FamiliM First Coronaviru.a ReepoD18
Act (Pub. L 116-127}.
h. Do independent contracton count as
employees for purp0188 of PPP loan
calculatioua 1
No, independent conb'actora have the
ability to apply for a PPP loan on their
own 10 they do llot count for purpoaea
of a borrower's PPP lo.In calculation.
i. What ia the interest rate on a PPP
loanT
The int81'88t rate will be 100 ~
pointl or one percent.
The Administrator, in COD1ultation
with the Secretary, determined that a
ODe percent intereet rate 11 appropriate.
Pint. it provides low coat funda to
borrowers to meet el.lgible payroll coats
and other ellgible expen.aea durtns thil
temporary period of economic
dislocation cauaed ~ the coronavinl1.
Second, fur lenders, the 100 haais points
offitn an attrllctive lnm'98t rate relative
to the eo1t of funding for comparable
maturilli!a. For u.ample, the FDIG'a
weekly national IVIIJ:'888 rate for a 24-
month CD depoait product for the week
of March 30, 2020 ia 42 buia points for
non-jumbo and 44 b11il pointa for
Jumbo (http.i/lwww.fdic.,ov/
regulatJonsll'fl«Jurc;e,lratt,sl). Third, the
interest rate la b1gher than the yield on
Treaaury 11eeurities of comparable
maturity. For example, the yield on the
Treasury two-year note ii approximately
23 buis poinu. Thia higher yield
combined with the fact that the loam
ere 100 peroent guaranteed by the SBA
and the £act thatlenden will receive a
aublltan.tial processing fee from the SBA
provide ample inducement for lcmden
to participate in the PPP.
j. What will be the maturity date on a
PPP loan?
The maturity 11 two years. While the
Act providea that a loa will have a
maximum maturity of up to ten years
from the date the batrower applies for
loan forgivaneaa (delcribed below), the
Administrator, in comultation with the
Secretary, determined that a two year
loan teem I.a 1umcient in lisht of the
temporary economic dislocationa
cauaed by the coronavirul. Specifically,
the oomiderable economic disruption
ceUHd by the coronaviru.s ii expected to
abate well before the two year maturity
date such that borroWtm will be able to
re-commence buain111 operations and
pay off any out.atanding balances on
their PPP loans.
k. Can I apply for more than one PPP
loan?
No. The Adm.inlstrator, in
conaultation with th& Secretary,
detemuned that no eligible borroW81'
may n,ceive more than one PPP loan.
Thill means that if you apply for a PPP
Paqe 12
loan you should CODSlder applying for
the maxhnum amount. Whtie the Act
dOM not axpreuly provide thet each
eligible-borrower may oDly receive one
PPP loan, the Admin.iatrator has
dt,ten:nined, in con,.ultation with the
Secretary, that becauN all PPP loans
must be made on or before June 30,
2020, a ODe lom per borrowar limitation
ia llecellU'J to help ensure that u many
eligible borrowen u possible may
obtaJn a PPP lou. Thia limitation will
also help advance Congress' goal of
keeping worken paid and employed
acrou the United States.
L Can I use e-algnaturea or e-oonsents if
a borrower haa multiple ownen?
Yea, e-aignature or e-conaenta can be
u,ed regardle,a of the number of
owners.
m. Ia the PPP "fint•come, 6m-88l'Ved1"
Yes.
n. When will I have to begin paying
principal and int8l'Nt on my PPP loan?
You will not have to ma.b any
payment, for six montla followiDg the
date of dilbunement of the loan.
However, int91'91t will continue to
accrue on PPP loans during thi• six-
month deferment. The Act authorizes
the Admini.atrator to defer loan
payments for up to one year. The
Adminiltrator determined, in
consultation with the Secretary, that a
six-month deferment period i1
appropriate in light of the modest
intmut rate (one percent) on PPP 108JLII
and the loan forgiveDee1 provilioDI
contained in the Act.
o. Can my PPP loan be foJSiven in
whole or in part?
Yes. The amount of loan forgiveneu
can be up to the full prlnclpa} amount
of the loan and any acc:ru.ecl interest.
That la, the bormwer will not he
reapon•ible for any loan payment if the
borrower Ul6I all of the loan proceed.,
for foJSl.veable purpoeea cte.cribed
below and employee, and compenaation
levels are maintained. The actual
amount of loan forgivane11 will depend,
in part, on the total amount of payroll
coats, payments .of inten,at on mortpge
obligattom incurred before February 15,
2020. rentpaymenll on leases dated
hefon, February 15, 2020, and utility
payment, under service agreements
dated before February 15, 2020, over the
eight-week p«lod following the date of
the loan. Ho-.ver, not more than 25
percent of the loan fc,rzivmeu amount
may he attribu.tahle to non-payroll coats.
While the Act providel that borrowers
are ellgible for forgiven811 in an amount
equal to the aum of payroll costs and
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'20814
Federal llllgi9ter/Vol. 85. No. 73/Wednesday, April 15, 2020/Rules and Regulations
any payments of mortgage interest, rent,
and utilitlaa, the Admloiatrator has
determintld that the non-papoll parUQn
of the fcqivabft"l~ aJDOµSlt -11.<lU!d be,
~tedto afi'act\.tateihe core purpo,e of
the 1taMe and emwe finite program
~IOlircet are· devoted prlmarlly to
payroll. The Administr:ator bu
detannined in couultation with the
~tqt 15 • l
·• .llaui
appropriate ~in'Ugbt of the
Act'• ovararchina focut on bepiDg
workers pa.id Gd employed. Further,
the Adm1Diltrator ana the SecMtary
be,lieve that applying thi1 tbreahold to
loan fmgivenea ill conaiatent with the
atru.eture of the Act, which provides a
loan IIDU)Wlt 'Et
of whjch is
equivalent to
. • t weeks of pay:wll (6
weeb/2.s mon
• 56 days/78 days.
74 pe.roent rounded up to 15 percent).
Limiting non-payroll coats to 25 percent
of the forsiveneu amount will align
theae elamenta of the ~.
and will
a1ao hel_p to 8114'Llr8 that the ftnite
approp;rlationa available for PPP loan
forgivenN1 ue directed toward payroll
protection. SBA will faaue additional
guidance on loan forgivenesa.
p. Do,indepen~t oontnc:ton count as
employee, for ptupoaea of PPP loan
forgiWDNI?
No, independent contractor• have the
ability to apply for a PPP loan OD their
awn 10 they do ®t count for purposes
of a borrower'• PPP loan forglveneu.
q. What fonm. do I need and how do I
aubmlt an application?
The applicant mult submit SBA Form
2483 (Paycheck Protection Program
Application Fol'tll-) and payroll
docmnantat1on, u daecribed above. The
lender mult submit SBA Form 2484
W.ychsck P;rotQCtton Program Lender's
Application for 7(a} Loan Guaranty)
electrol1ically in accord&nce with
pr08f&ID requlremanta and maint.atn the
forms and ,uppordng document.aUon In
ibflles,
.,
.~ --~'
•mJ-,~JQ~
~tii't'.bt.A~t
1
~
·,
ft,qt
~ .
.
,.
w~
v/J'tllft
v,.udU
~~pl~on"tlly<ithet
:=:=~=~
vii. refinanclq an SBA EIDL loan
:made between January 31. 2020 and
April 3, 2020. Jf you received an SBA
lDDL loan from January 31, 2020
through April s, 2020, you can apply far
a PPP loan. If your EIDL loan wu not
used for payroll coats, it doea not affect
your eligibility for a PPP loan. If your
EIDL loan wu med for payroll costs,
your PPP loan mu.at be 111ed to refinance
your EIDL loan. Proceedl from any
advance up to $10,000 on the EIDL loan
will be dedueta.d from the loan
forgiveneaa amount OD the PPP loan.
t\\r. -~
-. "" • ~-·.:tt·~,;~~·
M-~~•hi1ltli'iii<l tot-
~
. 90'~• For pUl'poe81 of
determining the percentage of u• of
proceed, for payroll COits, the .mount
of an EIDL refinanced will be inchided.
~
..
·.ui1u.utft'
'w'i:;~n
.• tbe am&)UD{
• ··the·~
-,,,, •• · - :
<'
..
·,j.
·,
.
. • & pa
J)Ollt,J
,:::=r~~
GQl..P,loyed,. As with the similar
limitation on the forgiven&1a amount
explained earlier, the Ac:lm1nistntor, in
conaultetiQil with the Secretary, baa
determined that 75 percent ia an
appropriate percentage that will elign
this element of the program with the
}08ll amount, 75 ~t
of which is
equivalent to eight weeb of payroll.
Thia llmlta.tion on Use of the loan funds
will help to 9lllNNI that the finita
appropriation, available for thNe loan.s
are d:iracted toward payroll protection,
as each loan that la luued deplete, the
appropriation, n,p:rdlen of whether
portiona of the loan a.re later forgiven.
s. What happens if PPP loan funds are
mlsusedT
If you use PPP funds for unauthorized
purposes, SBA will diri,ct you t.o repay
those amounts. If you knowlngly 111e the
funds for unauthori7.ed purposea, you
will be subject to ad,ditiODal liability
such u clwpa for fnud. If one of your
ahai'ehold8l'II, members, or partners \WIii
P:PP funda for unauthorized purposes,
SBA will have recoune agaimt the
shareholder, member, or partner for the
unauthorized use.
PaQe 13
t. What certifications need to be made?
On the Paycheck Protection Program
application,anauthorized
mp1'81entative of the applicant must
certify in good faith to all of the below: t
l. The applicant wu in ·operation on
February 15, 2020 and had employees
for whom it paid Hlarle1 and payroll
taxes or paid indapendent contractors,
111 rep<>rtltd on a Form 1099-MISC.
ii. 'Cummt economic uncertainty
mu.ea thia loan reque,t necenary to
support the OQBOiD8 operatiom of the
apP,licant.
di. The funds will be used to retain
worken and maintain payroll or make
mortgage interest payment.a, lease
payments, and utility p.ayments; I
understand that if the f'l;md11 are
knowingly uaed for unauthorized
purpoaea, the Federal Government may
hold me legally liable such as for
clwpe of fraud. As explained above,
not more than 25 percent of loan
proceeds may be used for non-payroll
costa.
iv. Documentation verifying the
number of full-time equivalent
emplo}'eN on payroll ea well aa the
dollar amounts of payroll costs, covered
mortgage interest payments, covered
rent payments, and covered utilities for
the eight week paiod following this
loan will be provided to the lender.
v. Loan fol]liveneu will be provided
for the IIWD ol documented payroll
costs, covered mortgase int9191t
payments, covered rent payments, and
covered utilities. As explained above,
not more than 25 percent of the fmgiven
amount may be for non-payroll COits.
vi. During the period b~ing on
February 15, 2020 and ending on
December 31, 2020, the applican.l haa
tlQt and will not l'9081ve another loan
under thu program.
vii. I further certJfy that the
information provided in this application
and the Information provided in all
111pportlns d.ocumenta and fnnDB is true
and ac~e in all material tetpecta. I
undentand that knowingly making a
fal88 statement to obtain a suaranteed
loan from SBA is puniahahle under the
law, including under 18 U.S.C. 1001
and 3571 by impriaonment of not more
than five years and/or a fine of up to
$250,000; UJ1der 15 U.S.C. 645 by
imprisonment of pot more than two
years and/or a fine of not mote than
$5,000; and, if 1111bmittad to a federally
insured institution, und8l' 18 U.S.C.
1014 by imprisonment of not mon, than
thirty Y8111'11 and/or a fine of not more
than Sl,000,000.
• ,. ~"
of lb. appllaqlt CU1 eesUfy for
tho~•• whole If Iha n,pr,Nmtatl11e i.
Mpll:, 11\lthoriNd lo do IO,
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208.1:5
viii. I acknowledge that tha lender
will confirm the eligible loan amount
entt I have-submitted.
,, ·-
_ .. ·~
,
. -~jljj
,
I alao
undentand, acknow e e, and .agree
that the Lander can share the tax
infonnatioo with SBA'• authorized
n,pre1entativu, mcludiog a-..tborized
n,prmentatiV89 of the SBA Office of
Inapector General, for the purpoae of
compllaDce with SBA Loan Program
Requlmnant, md all SBA reviews.
3. What do lenders need to know and
do?
a. Who ii aligl'ble to make PPP loans?
I. All SBA 1(a) lendera are
automatically approved to make PPP
loam on a delegated buia.
11. The Act providN that the authority
to make PPP loam can be extended to
additional lenden determined by the
Adminlatrator and the 8ecrftary to have
tha neceilary qualfficationt to prooeaa,
cloee, dlebune, and aervtoe loans made
with the SBA guarantee. Since SBA ia
authorized to make PPP loana up to
$349 billion by June 30, 2020, the
Adminstntor and the Secretary have
jointly datenmned thet authorizing
additional lenden ia neceuary to
athiev1t the purpoae of allowing u
many eligible borrowers u possible to
n,ceiva loena by the June 30, 2020
deadline.
iii. The follo~ type, of lendera
have been dstmnined to ~
the
criteria and are eligible to make PPP
Joana unleN they cunently .am
dl!llllgnated in Troubled Condition by
their primary Federal ngulator or are
111b1ect to a fot:inal enforcemapt action
with their p:rhnuy Federal reaulator that
addreuee umate or Ulllo'und lending
pncticsa: .
I. Any federally lmured depository
inltltution or any federally insured
credit union;
ll Ally Flll'ID Credit System Institution
(other than the Federal Agricultunu
Mortne Corporation) aa defined in 12
U.S.C. 2002(a) that appliea the
requirements undet the Bank Secrecy
Act and lta implementlna r,gulationa
(collectiffly. BSA) u a federally
regulatecl ftnancia) institution, or
functionally equlvaleot requiremente
that ue DOt altered by thia rulei and
m. Any depository or non-depository
ftnaoctng provider that origl.DatBI,
maintlina, and aervk:el busineaa loau
or other commercial financial
receivablea and participation inta:98ta;
bu a formalizea compliance program;
applies the n,quiremente under the BSA
ua.fedenllyregulatedfinanclal
inmtution, or the BSA requirements of
an equivalent federallyngulated
financial inltltution; bu been operating
since at least February 15, 2019, and bu
originated, maintained, and aarviced
mare than $50 million in buainea, 108Jl8
or other commercial financial
reomvablea durina a conaecutive 12
month peri()d in the put S6 month1, or
is a aervice provider to any insured
depoeitory iutitution that bu a contract
to support auch inat1tut1on'• lending
activitia In aooordmce with 12 U.S.C.
1887(c) and ..is in sood standing with the
aPJ>ropri~te Federal bank.inst 11,sency.
JV. Qualified imtitution, aeacribed Jn
3.a.iil.I. and n. will be automatically
qualified u.nder delegated authority by
the SBA upon transmillion of CARES
Act Section 11'02 Lender Agreement
(SBA Form 3506) unleu they currently
are dealpated in Troubled Condition by
their primary Federal regulator or are
•ubject to a formal enforcement action
by their primary Federal mgulator that
addreuea UDaafe or unsound lending
practices.
b. What do lenders have to do in terms
of loan underwriting?
Each lender ahall:
L Confirm receipt of borrower
certifications contained Jn Paycheck
Protection P:rogram Application form
i81Ued by the Admlni1tration;
ti. Corifirm .receipt of information
demonstrating that a borrower had
employees for whom the borrower pald
salariea and payroll taxe1 on or around
February 15, 2020;
ill. Confirm the dollar amount of
average monthly payroll C08lt for the
prece~· calendar year by reviewing
the pa,
documentation euhm1tted
with . borm"'8r'• application: and
iv. Follow appllcab]e BSA
requiremanta:
L Federally iuured depository
iultitutiona and led..Uy inau:red credit
uniona ahould continue to follow their
existing BSA protocols when making
PPP loam to either new or exiating
cuatomer1 who are eligible borrowem
llllder the PPP. PPP loam for existing
customers will not require re-
verification 1mder applicable BSA
requirementa, unleu oth81'Wite
indicated by the inltitution's risk.lbased
approach to BSA compliance.
n. Entities that Qe not preeently
subject to the requiNmumt& of the BSA,
should, prior lo lll\fNJng In PPP larullng
activitiea, including making PPP loana
to eithor new or exiating cuatomen who
are eligible bonowen undar the PPP,
Mtabliah an anti-money laUDdering
(AML) compliance prosram equivalent
to that of a comparable fede:rafiy
regulated institution. Depending upon
Paoe 14
the comparable ledarally regulated
iudtution, ruch a program may include
a cuatomer tdenttflcatic,n p.iogram (CIP),
wbtch includes identifymg and
verifying their PPP borrowara' identiti&1
(iincludiq e.g., date of birth, add:reea,
and taxpayer tdeutification number),
and, if that PPP borrower is a company,
following any applicable beneficial
ownerahip information collection
requinmeote. Alternatively, if available,
entitiel may rely on the CIP of a
federally lnlllll'8d depoaltory institution
or federally imured credit unlon with
an eatabllabed C1P u part of its AML
PJ'08l'UI1· In either inlltance, entities
ebould alao undemand the nature and
pu:r-poae of their PPP customer
relattonBhJpa to develop cturtomer risk
profllea. Such 8lltitiu will al,o
ganenilly have to identify and report
cartain 9U1pic:iou1 activity to the U.S.
Department of the Treuury'a Financial
Crimea Enfomem8llt Network (FlnCEN).
If auch mtltiea have queations with
n,gard to meeting thees requirementa,
they should contact the FinCEN'
Regulatory Support Section at FRCO
fincen.gov. ln addition, FlnCEN bu
created a COVID-19-speclfic contact
channel, via a 1peclfic drop-down
category, for entitf88 to communicate to
FinCEN COVID-19-fl!lated concerns
while •dbering to their BSA obligations.
.Entitl• that wish to communicate such
COVID-1,9-related ooneanu to Pin.GEN
ebould go to www.FinCEN.gov, click on
"Need J\asietance," and select
"COVIDl 9" iin the subject drop-down
lilt.
Bach lender's underwriting obligation
under the PPP 18 limited to tha items
above and reviewing the "Paycheck
Protection Application Form."
narrow ... fllutt 111bmit such
documentation as is neoeasary to
establlab eligiblllty •uch as payroll
pl'OC8880r record,, payroll tax fllinss, or
Form 1099-MISC, or income and
expenaea from a sole proprietorship. For
borrowers that do not have any such
documentation, the borrower muat
provide other supporting
documantatlon, such u bauk records,
<1uffldant to demonatrate the qualifying
payroll amount.
c. Can lenders rely on borrower
documentation for loan forgiveneasr
Yu. The lender doee not need to
conduct any verification if the borrower
submit, documentation euppotting its
request for loan flltgiv.en.e11 and attests
that it has aCCUtetely verified the
paJ::: for eligible costs. The
Ac •
• trator will hold harmleu any
lender that relies on such bon:ower
documents and attestation from a
borrower. The AdminJ,trator, in
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consultaUon with the S8CN1tary, has
detBrminacl that lender ?8UIUlce on a
bomrwr, required documents and
atteltation la ottceuary and appropriate
in light of 1ectfon 1:106(h) of the Act,
which prohibits the Administrator from
taking an enforcement action or
impoo.ng penaltiee If the lender bu
received, a borrower attestation.
d. What &e. will lenders be paid?
SBA will ~y lenders t'89I for
pmcening PPP loam in the following
amounts:
i. Five (15) percent (or loans of not
more than $350,000;
il. Three (3) percent for loans ohnore
than $350.,000 and leu than $2,000,000;
and
ill. Ona (1) percent for locm of at leut
S2,000,000.
e. Do lend.9l-l have to apply the "credit
elsewhere teat''?
No. When evaluating 1111 applicant's
eligibility lenders will not be required to
apply the "credit elaewhere.test" (as aet
. forth In aection 7(a)(1)(A) of the Small
Busin911 Act (lli U.S.C. 636) and SBA
reguletiona at 13 CPR 120.tot)).
4. What do both borrowers end lenders
need to know and do?
a. What are the loan tenna and
candition,?
Loans will be gulll'IUlteed under the
PPP under the Alll& tsrmJ, conditions
and procatHS as other 7(a} loans. with
certain ~s lncludins but not
limitacl to:
i. The suamntee peramtage is 100
~~;
oollatenl will be requJred.
ill. No personal guarantees will be
NlCJ.uired,
av. The Interest rate will be 100 bu.is
points or one perilent
v. All loans will be proceeeed by all
lendsl under delegated authority and
lend8l'I will be pennitted to rely on
cartificatioll8 of the borrower in order to
determine eligibility of the bcmowar
and the use of loen. proceed•.
b. Are there an.y fee waivers?
f. There will be DO up-front guatantee
fee payable to SBA by the Bol'J'ower:
if. Tbere will be no lender'• annual
.ervice file ("all-going guaranty fee")
payable to SBA;
ill. 'l"hce will be no aub$idy
:recoupment fee; and
i:v. There will be no fee payable to
SBA £or any gus:nmtee aold into the
IIIICODdary mirbt.
c. Who paya the fee to an agent who
usillta a borrower?
Agant feei will be paid by the lender
out of the feei the lender receives from
SBA. Agents may not collect fees from
the borrower or be paid out of the PPP
108Jl proceeds. The total amount that an
agent may collect from the lender fo.r
assktance :in pre~ an application
for a PPP loan (l:ncluding referral to the
lender) may not exceed:
i. One (1} pen:ent for loans of not
mare than $350,000;
il. 0.50 percent for loans of more than
$350,000 and leu than $2 million; and
iii. 0.25 percent for loena, of at least $2
million.
The Act authorurea the AdminimatOJ'
to elitabliah limits on agent fees. The
Adminime.tor, In consultation with the
Secretary. detemunacl that the agent fee
limits set forth above are reuonable
based upon the application req
uirementa and the fees that lenders
receive for making PPP loans.
d. Can PPP Joans be sold into the
secondary market?
Y•. A PPP loan may be sold on the
secondary market after the loan ia fuJ}y
diabuned. A PPP loan may be aold on
the secondary marbt at a premium ot
a discount to par value. SBA will iaaoe
guidance reganllng any advance
purchaae for loam sold in the secondary
market.
e. Can SBA purchase some or all of the
loan in advance?
Yea. A lender may reqUBSt that the
SBA purchaae the expectacl furgiveneaa
amount of a PPP loan or pool of PPP
loam at the end of week 1even of the
covered period. The expectacl
forgiveneaa amount is the amount of
loan prind~ the lender reasonably
expects the borroW11r to expend on
payroll costs, covered mortaege interest,
covered nlllt, and covered utility
payments during the eight week period
after loan diabursemenL At least 75
percent of the expected forgtveneu
amount •ball be for payroll co,t,, a,
provided in 2.0. To submit a PPP loan
or pool of PPP l08Il8 for advance
purchaae, a lender ,ball submit a report
requeating advance purchue wtth the
expected 1'orgivene111 amount to the
SBA. The n,port ahall include: the
Paycheck Protection Program
Application Form (SBA Form 2483) and
any 1upporttns documentation
submitted with mcb application; the
Paycheck Protection Program Lender's
Appllcation for 7(a} Loan Guaranty
(SBA Form 2484) and any supporting
documentation: a detailed IW'l'ative
explaining the 1181Wllptiona med in
deter'miniug. the expect ad forgivvnea
amount, the buia for tho• uaumptiona,
altemative a11umption, conaiden,d, and
why alternative auumptiona were not
w,ed; any information obtained from the
Paoe 15
borrower since the loan was diabu:raed
that the lender used to determine the
expected forgiveneu amount, which
should include the wne documentation
requind to apply for loan forgiveneu
such u payroll tax filings, cancelled
checb, and other payment
documentation; and any addiUcm.al
lnfonoation the Admlniatrator may
requin, to determine whether the
9Xpecied forgiveneaa amount i8
reuonable. The Adm1.nistrator, in
e01111ultation with the Secretary,
determf:nacl that ,even weeks is the
minimum period of time neceuary for
a lender to l'N80nably dets:rmine the
expected forgiveness amount for a PPP
loan or pool of PPP loans, since the PPP
is a new program and the likelihood that
many borrowers will be new clients of
the lender. The expected forgiveness
amount may not exceed the total
amount of principal on the PPP loan or
pool of loana. The Administrator will
purchase the expected forgiveness
amount of the PPP loan(e) within 15
day.- ofthe date on which the
Administrator receives a coxnplete
report that demonstrates that the
expected Corgiveneu amount is indeed
reasonable.
5, Additional Information
All loe.m guaranteed by the SBA
pursuant to the CARBs Act will be
made conahtent wtth constitutional,
statutoiy, and regulatory pmtectiODB for
religiou• Uberty, including the First
Amendment to the CODltitution, the
Rellglo111 Freedom Restoration Act, 42
U.S.C. 2000bb-1 and bb-3, and SBA
regulation at 13 CFR 113.3-lh, which
provides that nothing in SBA
nondiacrimination regulations 1ball
apply to a n,llgfoua oorporation,
a11ociaUon, educational inatltution or
society with reepect to the membership
or the employment of individuals of a
particular religion to perform work
connected with the carry:lns on by tut:h
corporation, astociation, educational
institution or society of its religious
activitiea. SBA intendt to promptly
issue additional guidance with regard to
religioua liberty protections. under this
program.
SBA may provide further guidance, if
needed, th.rough SSA notices and a
program guide which wlll be poated on
SBA'• website at www.ma.aov.
Queetiooa on the Paycheck Protection
Program 7(a) Loans may be directacl to
the Lender Relationi Specialist 1n the
local SBA Field Oftice. The local SBA
Field Office may be found at https:/1
www.flKl.~vltool1flocal-aui6tance/
di6trictof11ces.
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•
•
Federal Itepter/Vol. 85, No. 73/Wednesday, April 15, 2020/Rules and Regulations
2081'1
Compliance With .Executive Orders
12898, 13981, 13132, and 13771, the
Paperwork lblchl«;dcm Act (<M U.S.C.
Cb. 31), ad tblt llaplatory.Flmbilily
Act (5 U.S.C. 801-411Z)
E.O. U866 and E.O. 13583
This interim final rule is
economically 1iptflQ1Dt for the
plll'pOH9 of Executive Ord.an 12866 .and
13563. SBA, however, is prooeeding
under the amargency provision at
Executive Order 12868 Section
6(a)(3XD) baaed on the need to move
expeditioualy to mitigate the current
economic conditiona arialng from the
COVID-19 emergency. Thia rule'•
de,Jgnation under Executive Order
13771 will be informed by public
comment.
This rule is neceaaary to implement
Sections 1102 and 1106 of the CARES
Act in m:der to pJ;OVide ec;onDlJlic relief
to amall buaineuee nationwide
advereely impacted under the COVID-
19 Emergency Declaration. We
anticipate that Um rule· will relUlt in
su~tantiill benefit. to aJ;11all buatneuea,
their employeea, and the communities
they Mn'8. However, we, lack data to
eatimate the eff&ct.t of thit rule.
Executive Order 12988
SBA bu drafted this rule, to the
extent practicable, in accordance with
the standards aet forth in section 3(a)
and 3(bX2) of~tlve Order 12988, to
minimize litigation, el1minate
ambiguity, and reduce burden. The rule
bu P.Q preemptive or retroactive effect.
Execut:hm Order 13132
SBA hu determined that thia rule
will not have subatantial direct effecta
on the States, on the relationship
betwemi the National Government and
the States, Of on the dllltribution of
power and responsibilitiea among the
varloua layers of government The:refore,
SBA bu determined that this rule baa
no federall1m lmplicatiom wernmtiog
pntpantion of• &demlism useesmenL
Paperwork Reduction Act, 44 U.S.C.
Chapter35
SBA bu dtJtenxiined that tbia rule
will impose recordkeeping or reporting
requirements under the Paperwork
Reduc::tion.Act ("PRA"). SBA bu
pbtamed er.tlelgency approval under
0MB Control Number 3245-0407 for the
information collection (IC) required to
implement the program d88Cl'ibed
above. This IC couiats of Form 2483
(J>•ychack Protact:ian PrQB1'8Jn
Application Form), SBA f'onn 2484
(Paycheck. Protection Program Lender's
Application for 7(a) Loan Gwuanty),
end SBA Fonn 3506 (CARES Act
Section 1102 Lender Agreement), and
SBA Form 3507 (CARES Act Sectioo
1102 Lender Agreement-Non-Bank and
Non-Insured Depository lnstitution
Lender). Tho collection is approved for
u,e until September 30, 2020.
Resulatory Fluibillty Act (BFA)
The Regulatory FlexibtUty Act (RF A)
genenlly requires thet when an agency
USU88 .a propoaed rule, or .a final rule
punuant to section 553(b) of the AP A Of
an.other law. the aaency must prepare a
regulatory flexibility analysis that meets
the requirements of the RF A and
publish such analy1is in the Federal
R.epter. 5 U,S.C. 603,604, Speci6cally~
the RF A nonnally requires agencies to
describe the impact of uulemekJng nn
amall entitles by providing a resuJatory
impact analysu. Such analysts mu.t
admeas the consideration -of regulatory
options that would leuen the economic
effect of the rule on amall entities. The
RFA defines a "small entity" as (1) a
proprletary firm meeting the size
,standards of the Sl118ll Businees
Adminiatration (SBA); (2) a nonprofit
Ol]IUlization that is not dominant in its
field: or (3) a amall government
jwiadiction with a population of leu
than so.ooo. s u.s.c. 601(3H6). Except
for 11uch small government jurladictiona.
neither State nor local govemments are
•••mall entitiea." Similarly, for purpoae.
of the RF A, iodividual pert0ns are not
amall entitlea.
The requirement to conduct a
regulatory impact analysis does not
apply if the bead of the agency "certifies
that the rule will not, if promu18'1ted,
have a signifiC8Jlt economic impact on
a suhatantial number of amall entities."
5 U.S.C. 605(b). The agency must,
however, publlah the cartiftcation in the
Federal .Repter at the time of
publication of.the rule, "aloq with a
statement providing the factual basis for
such certification." If the agency bead
has not waived the requirements for a
n,guletory flexibility analy1i1 in
accord!Ulce with the RFA~s waiver
provision, and no other RF A exception
applies, the apncy must prepare the
regulatory flexibility analy1il and
publiah it in the Federal~ at the
time of promulgation or, if the rule ia
promulgated in :c:'8 to IUl
emtqency that
timely
CQmpliance impracticable. within 180
daye of publication of the final rule. 5
U.S.C. 604(a}, 608(b).
Rules that ue exempt fl'Qm notice and
com.mat are also exempt .&om the RFA
requirement,, lncludini conducttng a
regulatory flexibility analyslt, whvn
among other things the agency for good
cauae 6nda that notice and public
procedure ans hnpmctk:able,
Paoe 16
unneceaaary, or contrary to th.a public
intere,t. Smell Buain88a
Adminittratlon's Office of Advocacy
guide: How to Comply with the
RfltJll}atory Flexlbillty Ac. Ch.1. p:9.
Accordingly, $.PA la not requifttd to
conduct a regulatory flexlbltity analy.ts.
Authority: 15 U.S.C. 636(aJ(36);
Corcmavirus Aid. Relief, fllld Economic
Security Act, Public Law 116-136,
Section 1114.
Jmta Cammza,
Admlnlstratnr.
(PJl Doc. :1020-07872 Filed 4-10-:lO; 4:15 pm]
IIIU:IICI COOE p
$MALL BUSINESS ADMINISTRATION
130F-R Part 121
[Doolm No. SBA-2020-0011]
·RiN S2A5-AHl5
BUii,... Loan Pl'OQIJlffl Temporary
C..,..; Paycheck Protacitlon
Pn,gram
AGl!NCY: U.S. Small Buaineu
Admlniatration.
ACllON: lnte,rim final rule.
SUMMARY: Elaewhere in this iaaue oftbe
Federal llepilm, the U.S. Small
Buai.neaa Administration (SBA) ia
publiahlng an interim final rule (the
Initial Rule) annou.nclna the
hnplementatlon ohect:iona 1102 end
1106 of the Coronaviros Ald, Relief. and
~auc Securlty Act {CARES Act or
the Act}. Section 1102 of the Act
temporarily add, • new program, titled
the "Paycheck Protection Program.'' to
the SBA'a 7(a) Loan Program. Section
1106 ofthe Act provides for fotgivenen
of up to the full prin.cipal amount of
qualifying loana guaranteed under the
P-,check Protection Program. The
P.aycheck Protection Program and loan
forgiven.es• are intended to provide
economic relief to amaJI buain81188
nationwide advenely impacted by the
Coro.navirwa Di.Male 2019 (COVID-19).
'1.1bit interim final rule 1Upplementa the
Initial Rule with additional guidance
regarding the application of certain
dfiliate zulet applicable to SBA's
implementation of section.a 1102 and
1106 of the Act and requests public
comment.
DATU:
Bffectlve date: This inta'im final rule
ia effective Af.ril 15, 2020.
App1icabWty dam: Thia interim final
.rule appli• to applicatiom submitted
under the Paycheck Protection Program
through June so, .2020, or until funds
made available for this purpoee are
exhausted.
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Case 1:22-cr-00171-MLB-RDC
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Page 53 of 66
There isn't a single average income for U.S. citizens in African mining, but
salaries vary widely by role, experience, and location, with highly skilled
~ professionals like Mine_Managers earning significantly more than entry-level
positions, often on a comparable or higher level to mining-intensive nations like
Canada and Australia. A general salary for a Mining Engineer could range from
$90,000 to $160,000 annually, with compensation packages frequently
~
including benefits and housing, though specific figures for the African context
are not provided. 0
Factors influencing income:
Job role:
Salaries differ greatly by position, from management and engineering roles to more
technical or entry-level positions. 0
Experience and skills:
Highly skilled and experienced professionals command higher salaries. 0
Location:
While no specific African average is given, salaries are generally highest in mining-
intensive countries such as Australia and Canada, suggesting a similar trend in
Africa. 0
Company and benefits:
The specific mining company and any additional benefits, such as housing or expatriate
allowances, significantly impact the total compensation package. 0
Examples of high-paying roles:
Mine .. Managers:
High demand for these professionals in mining countries like Zambia and South Africa
can lead to high salaries. 0
Mining Engineers:
These technical roles are highly valued and can have annual earnings ranging from
$90,000 to $160,000, according to Mining Review Africa. 0
Project _Directors:
Roles in project management and operations are among the highest paying in the
industry. &
Highest Paying Jobs in the Mining Industry (2025 Update)
Jun 19, 2025 -
let's explore the toµ-paying roles in today's mining workforce. • Project Director
nrillitHI r .
j, ,,
r Y,., ,. ,
8
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Case 1:22-cr-00171-MLB-RDC
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Page 54 of 66
There is no single "average pay" or annual income figure for Chinese-operated
mines in Africa, as it varies significantly by country, mine, and position, but
Chinese mining firms in Africa often pay higher wages to their local workforce
to attract and retain talent and secure better local community relations. Data on
the profitaoility or revenue of individual mines is scarce, but Chinese firms have
invested bitUons in African mining, particularly for minerals like copper and
cobalt. tP
Factors influencing pay and income
CtJ~!!Y.J!~_gJo~~• .. !;.2n~xt;
Salaries will differ significantly between countries like the DRC and South Africa,
depending on local wage standards, cost of living, and m:inimum wage laws. &
~~!t!'_Q1!_tn.JL!.~~m;.
Pay rates vary by job, with skilled positions like geologists and engineers earning more
than unskilled laborers.
~ome_~-~Y...,P.~.ll~Y.:;.
I
. Some Chinese companies offer higher wages for their local workforce than other ,
employers, as a strategy for community relations and talent acquisition. &
\ '
Commocfily prices and market conditions:
The revenue and profitability of mines, and thus their capacity to pay, are directly
impacted by global commodity prices. &
Examples of Chinese operations in Africa
o Chinese companies, such as ,Q.h.!D.~_.M9..!)'bdenurn and ~~j~§l_r:!a.!:i.U..~Y.2:Y __ g.;.q_~~!~, have
become major players in cobalt and copper mining in the Democratic Repubtic of
Congo (DRC). 0
o In South Africa, companies like Sin.2.§!.!~1 and Zijin_MiQ~rtg have a significant presence
in the mining sector. 0
Why a clear "average" is difficult to find
Confidenti•lity:
Companies typically do not disclose specific salary data or financial performance of
• their mines, making it difficult to establish a meaningful average. &
Data tr-agmentatton:
Information is spread across various reports, academic studies, and news articles, and
a centralized database tracking all Chinese mining operations and their finances in
Africa is not available. &
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 61 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
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Page 56 of 66
There is no singte "averag,e income" for a Chinese operation in Africa, as
incomes vary significantly ~y country, sector, and the type 9f worker (Chine.se
expatriate vs. local staff). However, research indicates that Chinese firms in
some African countries, like Ethiopia, have P"id median wages higher than
domestic firt11s. Wages can also depend on factors such as the firm's
profitability, capital investment needs, and its strategy for attracting high-quality
workers. @
Factors Influencing Income cf'
Country and Sector:
Wages differ greatly between countr1es and industries, with major investments in
sectors like energy, mining, construction, and trade.
Worker Type:
Compensation for Chinese expatriate workers is often higher than for local African staff.
Ftrm Sttategy:
Some Chinese firms pay higher wages to attract skilled workers, while others have
lower wages, perhaps compensated by job stability.
Profltablllty and Competition:
Lower wages might occur in sectors with tight profit margins or in firms subject to fierce
competition, especially in small and medium-sized enterprises.
Capital tnvr:tstment:
In sectors requiring large initial capital investments, such as miningj firms may initially
have lower wages while recovering costs.
Examples and Data e>
.~J!!.l~e.~.:
I
. fA 2012 World Bank survey found that median wages in Chinese firms were 60% higher ·,
than in domestic Ethiopian firms.
Gha~n•:
, At a Cfiinese ceramic manufacturer, wages for Ghanaian workers were above the
, nationaJ minimum
age.
~mbl~:
,
A study in Zambia's mining sector found that lower wages were sometimes offered, but
this was offset by greater job stability.
l.
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 62 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 57 of 66
In summary, the income for a Chinese operation in Africa is not a fixed figure
but is shaped by a complex interplay of market forces, company strategy, and
the broader economic conditions within the host country. &
Chinese firms and employment dynamics in Africa: A comparative ...
In a 2012 World Bank survey of firms ln Ethiopia, median wages in Chinese firms
were 60% higher 1han in domestic firms (Bashir, 20 ...
A Asociacl6n Almendron
Africa-China economic relations - Wikipedia
Its economic interests in Africa have increased dramatically since the 1990s. The
most prominent Chinese corporate actors are stat...
W Wikipedia, the free encyclopedia
:
Africa's reliance on China is only likely to get worse
Jan 26, 2023 -
China is now the African continent's largest trading partner,
accounting for $282bn in commerce in 2022. It Is also th ...
•
Investment Monitor
:
Show all
••
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 63 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 58 of 66
Here's how you know
fitIRS
Foreign ·earned income exclusion
If you meet certain requirements, you may qualify for the foreign earned income
exclusion, the foreign housing exclusion, and/or the foreign housing deduction. To
claim these benefits, you must have foreign earned income, your tax home must be
in a foreign country, and you must be one of the following:
• A U.S. citizen who is a bona fide resident of a foreign country or countries for an
uninterrupted period that includes an entire tax year,
• A U.S. resident alien who is a citizen or national of a country with which the
United States has an income tax treaty in effect and who is a bona fide resident
of a foreign country or countries for an uninterrupted period that includes an
entire tax year, or
• A U.S. citizen or a U.S. resident alien who is physically present in a foreign
country or countries for at least 330 full days during any period of 12
consecutive months.
You can use the IRS's Interactive Tax Assistant tool to help determine whether
income earned in a foreign country is eligible to be excluded from income reported
on your U.S. federal income tax return.
If you are a U.S. citizen or a resident alien of the United States and you live abroad,
you are taxed on your worldwide income. However, you may qualify to exclude
your foreign earnings from income up to an amount that is adjusted annually for
inflation ($107,600 for 2020, $108,700 for 2021, $112,000 for 2022, and $120,000 for
2023). In addition, you can exclude or deduct certain foreign housing amounts.
You may also be entitled to exclude from income the value of meals and lodging
provided to you by your employer on their premises and for their convenience.
However, such amounts are not foreign earned income. Refer to Exclusion of Meals
and Lodging in Publication 54, Tax Guide for U.S. Citizens and Resident Aliens
Abroad, and Publication 15-8, Employer's Tax Guide to Fringe Benefits for more
information.
Online tools and
updates
• International
taxpayers videos
• International
taxpayers news
releases
• International
taxpayers interactive
tools
Individuals topics
• Tools
• Taxpayer Advocate
• Affordable Care Act
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 64 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
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Page 59 of 66
• Other'rules
Forelsn-.eatned income: Foreign-earned income means wages, salaries,
profe5$ional fees, or other amounts paid to you for personal services rendered by
you. It does not include amounts received for personal services provided to a
corporation that represent a distribution of eamings and profits rather than
reasc>nable compensation.
Stlf-employment income: A qualifying individual may claim the foreign earn~d
incorne e>cclusion on foreign earned self-1!inpl,oyment income. The excluded
amount will reduce your regular income tax but will not reduce your self-
employment tax. Also, as a self-employed individual, you may be eligible to claim
the foreign housing deduction instead of a foreign housing exdusion .
.No,t forelcn flin,ecUncome: Foreign earned income does not include the following
•mounts:
• Pay received as a military or civilian employee of the U.S. government or any of
its agencies
• Pay for services conducted in international waters or airspace (not a foreign
couhtry)
• Payments received after the end of the tax year following the year in which the
seFVices that earned the income were performed
• Pay otherwise exctudible from income, such as the value of meals and lodging
furnished for the c<>r'lvenience of your employer on their premises (and, in the
case of lodging, as a condition of employment)
• Rension or annuity payments, including social security behefits
Fottip tax home: You may have a foreign tax home if your work is in a foreigh
country and you expect to be employed in the foreign country for an indefinite,
rather than temporary~ period of time. You do not have a foreign tax hotne if your
abode remains in the United States (where you keep closer familiat, economic, and
l)t!rsonal ties) unless you work in a Presidentiatly~eclared combat zone in support
of the Armed Forces ofthe United States. ·For more information, see Tax Home in a
• Foreign Country.
PiO,rin& the tax: If you qualify for and claim the foreign earned Income exclusion,
the foreign housing exclusion, or both, must ftgure the tax on yollt remaining non-
excluded .Uicome using the tax rates that would have applied had you not daimed
the exclusion(s). Use the Foreign Earned Income Tax Worksheet in the Form 1040
Instructions.
• Foreign Earned Income
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 65 of 134

• -
Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 60 of 66
• Tax Home in a Foreign Country
• Bona Fide Resident Test
• Physical Presence Test
• Exceptions to Tests
• Figuring the Exclusion
• Choosing the Exclusion
• Revocation
• Foreign Housing Exclusion or Deduction
• Individual Retirement Arrangements
• Extension to Claim Foreign Earned Income Exclusion
• Foreign Earned Income Exclusion and the Pine Gap Facility FAQs
Related
• Form 2555, Foreign famed Income
• Form 4868, Application for Automatk Extension of Time to File U.S. Individual
Income Tax Return
• Form 2350, Application for Extension of Time to File U.S. Income Tax Return
• Publication 54, Tax Guide for U.S. Citizens and Resident Aliens Abroad
Page Last Reviewed or Updated: 10-Jan-2025
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 66 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
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Page 61 of 66
How much overseas income is exempt from US taxes?
. However, you may qualify to exclude your foreign earnings from income up to an amount
that is adjusted annually for inflation ($107,600 for 2020, $108,700 for 2021, $112,000 for
2022, and $120,000 for 2023). In addition, you can exclude or deduct certain foreign
housing amounts. Jan 10, 202s
((I\ IRS
'. ·) https://www.irs.gov > indlvldu~ls > international-taxpayers
Foreign earned income exclusion I Internal Revenue Service
What is the stacking rule for foreign earned income exclusion?
The stacking rule ensures that any taxable income after applying the FEIE is taxed at the
correct marginal tax rate as if the excluded income were still inciuded . This prevents
taxpayers from artificially lowering their tax bracket by using the FEIE. Feb 13, 2025
6
~
~ Universal Tax Professionals
fl• ' https://universaltaxprofesslonals.com > the-stacklng-rule-h ...
The Stacking Rule: How to Optimize FEIE for Better Tax Savings
How many days can you work outside the US without tax implications?
Often, that threshotd is at least 90 days, and In countries that have tax treaties with the U.S.
(see the IRS page on Tax Treaties for additional information) the threshold for U.S. residents
is generally 180 or more days in a year.
{lit> , Columbia Finance - Cotum~ia University
https://www.finance.oolumb1a.edu > content > learn-about...
Learn about Taxes While Working Abroad - Columbia Finance
What is the tax exemption for US citizens living abroad?
If you claim the Foreign Earned Income Exclusion by filing IRS Form 2555, then you don't
have to pay tax on your first $126,500 of foreign income for the 2024 tax year (the exclusion
amount is $130;000 for the 2025 tax year).
,.
-
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 67 of 134

Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 62 of 66
Why do US citizens have to pay taxes abroad?
US ta>ces are based on citizenship rather than residence . This means that citizens are
taxed by the IRS even if they live in another country. The only way to avoid this tax system
is to renounce your citizenship, which can be costly and is rarely wise. Jun 2. 202s
~ ) Greenback Expat Tax Services
~ -
https://www.greenbacktaxservices.com > knowledge-center
Why Do I Have to Pay U.S. Taxes If I Live Abroad?
Do US citizens living abroad pay tcixes twice?
Double taxation occurs when someone is taxed twice on the same assets or stream of
income. US expats are often subject lo double taxation, first by the US, and again by their
country of reslde·nce. Jan a. 2025
(O \ Greenback Expat Tax Services
_'/ https:/lwww.greenbacktaxservlces.com > knowledge-center •
What Is Double Taxation-and How Can Expats Avo'id It?
What is the difference between Fonn 3520 and 709?
V
What qualifies as foreign earned income?
Foreign earned income is income you receive for performing personal services in a foreign
country. Where or how you are paid has no effect on the source of the income. M~r 14, 202s
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Case 1:22-cr-00171-MLB-RDC
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Page 63 of 66
To obtain records of payments made to the IRS by wire transfer, you can use
your IRS Online Account to view your account activity or request an official tax
transcript. A tax transcript is generally faster and free, while a full tax return
copy requires a fee. <P
Use the IRS Online Account
This is the fastest and most convenient way for individual taxpayers to v•ew tax
records, including payments. 0
• Access the account: Visit the IRS website and log in to your Online Accouht. You will
need to verify your identity through a service like ID.me.
• View records: After logging in, go to the "Tax Records" or "Payment Activity" tab to
see all payments posted to the account.
• Get a transcript: From the onllne account, you can also view. print, or download
a Tax Account Transcript, which shows all payment types, not just wire
transfers. "
Request a tax transcript by mall
If you cannot or prefer not to use the online service, you can request a tax
transcript by mail.
~
1. FIii out Fo.rm 4506-T: Complete and sign Form 4506-T, Request for Transcript of Tax
Retum.
2. Specify the transcript type: On line 6~ check the box for "Tax Account Transcript".
This will show all payment activity for the tax year requested.
3. Mall the fonn: Send the completed form to the JRS address llstea in the instructions.
The transcript will be malled to you within 5 to 10 business days.
cf/
Request by phone
You can call the IRS automated transcript service to have a tax account
transcript malled to you.
• Phone number: Call the IRS at aoo .. 908-9946.
• follow the prompts: Provide personal 'information as instructed.
• Receipt: The transcript will be delivered to the address the IRS has on file for you
within 5 to 10 calendar days.
@
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. . .
Case 1:22-cr-00171-MLB-RDC
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Page 64 of 66
What to do if the payment isn't shown
If your bank confirms the wire transfer was processed and debited from the
account, but it does not appear on your IRS transcript or online record, contact
the IRS by phone. The payment may have been misapplied, or the record may
not have been updated. tP
Business wire transfers
For payments made via the Electronic i:ederal Tax Payment System (EFTPS)
or for business accounts, you can access payment history by logging into your
EFTPS account or your IRS Online Account. For older .records, you can submit
Form 4606-T. e
What is an IRS tax transcript, and how do you request one?
Online request. The fastest and most convenient way to get a tax transcript is
,
,
online. Simply visit or create your online IRS account, navigate to the 'Tax Reco...
--~ <
~
-
•
H&R Block
:
Transcript types for individuals and ways to order them - IRS
Apr 2l, 2025-Ways to get transcripts. You may register to use Individual Online
Account to view, print, or download all transcript types listed below. If you're ...
(I IRS (.gov}
:
Direct Pay help I lntemal Revenue Service
Aug 28, 2025 -
Will Direct Pay work for me? • 1. What is Direct Pay? Direct Pay
Is a free IRS service that lets you make tax payments online directly from your ...
(it IRS (.gov} !
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Case 1:22-cr-00171-MLB-RDC
Document 240
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lll■Y oa,...-a dalay iD prooeeaing, nlllllt ill incorrect i.nfo~ti011. in your acoount, or -
c:llWI• )"0U to l:l-. a-■i.gmd -.:,re than ane l'.DI.
If the 1nfotat1on i■ not ~
<U ■hown
abc,v-e, pl .... ..im the correctioc Ulling the atcac:hild tear ot.f ■tub and :retw:n it to \la .
&and an the i:lltor9Atian ncaivad .fn,a Y0U or your ~tiw, you WJllt fil ■
the tollcwing f0%a(■) l1)' the datAII(■) abown.
Jo%11Hl
l"arat HO
a./30/2019
01/31/2019
If you bllv9 QUNtiOII■ alxlut the tara{■l or th■ du■ dat■( ■l ~, ycu can aell wi at
th■ phca■ JIUlllber or writ:11 to wt at the ~
■i- at tbe top of th1■ notice.
If you
DNd llelp in ~
your anaaal aeoounting period (tax y.ar), -
PubHc:■.ti011 518,
Aocounung hr1oda arid ~
-
W. ...
.f.gn■d you • tu cl.aM1Uoaticn bued en info~tian cibta~ ~%all you or y,:,ur
~ti'ft. It i■ not a l■gal det6zll1.m.ticn of your tu olanit:icatica, and i■ not
bioding CID the IRS.
If )'Oil -
• legal detuwinaticn of yow:- tax c:luai·flcatian, )'Oil -y
~t a pi-ivate lettn ruling froa t.he IRS uncSar tb■ guidelin■a in ...,,_ ~
200,-1. 2004-1 I.Jl,B. 1 (or ~
~
PrOcedure for t.M yar at i-} .
Jlote ,
c.rtain t.- c1-iUc.tic:Q el~ioD,■ can .be~
by fUizlg l'cn,a tU2, 9Qt1ty
e1 ... 1.r1cat1C11 Jllactioa.
See f'brlll 11832 aDl1 it• imtructicra for additiOIMll inrara.tiaa..
If you an nqu1red to depoeit for •■pl~
bl.De (!'o~ Hl, HJ, HO, H4, ,HS ,
cr-1, or 1042), u:ci .. ~
(Jl'or'a 120), or 1- taxi■• {Po:ral 1120), Y'0'2 will r908ift ••
Welc:ot11■ Pa0l<aga ■bortly, wbidl izlcludee inatructicra for •aaJdng )'Cll1" depo■it•
eletrQQically ~
th■ ll.«itroaic rtdlral ~
h)'llllAt lly■ta {D'l'll$) .
A hr■onal
1ct.ntific:ar.iC1111 .~
(PIR) "or ans will al■o he .-Jt to you ~
-NIP4ar■t• COYU".
1'1- activate tba .XII -
yot.> ,,_1,,. it, __,,_ if you ~
~ted tba nrvi.CM of •
tu prot-icmal or z,epx-.tiwi.
POJ: a:a:e in.t-tion about JDIT1'8, refer to
Publicaticn ,,,, &lectrauc .aiotou to Pay All rom- l'9cllarlll nus... rt you need to
Nita a dllpo■it ilaadietely, )"Oil will DNd to ..ice arr~• witb your Financial
In.9titutiOD to =-1?let• a nr. treater.
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 71 of 134

J.
•
Case 1:22-cr-00171-MLB-RDC
Document 240
Filed 09/08/25
Page 52 of 66
(DIS tJSB C1Q'tY)
575A
09-01-2018
10UIM
B 9999999999 SS-4
'1'.tle. IRS 1- ~tted to !lelpiJI; all~ CICll!PlY with their t- tiling
ol>liptiaaa. If you med ml:p ~latUI& your retuma or -.tiJI; ~
tax Clbligatiix.,
Autborl.Hd e~fUe hvlri.der•, web U Mporting Agant• (payroll Nrtic:ie psovidoml) are
6.'ftilabla to uai8t }"OU .
Vi•it tba lU lleb •ita •t -.in.gov for a Uat of ooapan1 ..
tllat iltfer na •-file for ~
l)rOduet• and HJ:Vi-c-. 'l'ba li•t pz'0'4dea ~.
talepbl:illlt l:IUllben, and UDD to thitir Web aitea.
'.l'o cbt.11111 tax form,a and publicatiaia, includi.il!J tboe4I ft%~ 1r1. tbia notice,
viait our~ ait• at -.1n.ggv. If you do not hav1I aoo- to tlae JnterQllt, call
1•800•829•3'76 (ffr/'ltl) 1•800·829-4059) ar viait your loc:,al IRS offi011 .
DIP(iftU!t! .. ,. *"'
•
k.Mp a CIC!PY' of th.i• ootic:ie in )'oUr puai:iant racioza.. ftl• 11iOtiOe 1 .• i.liaua4 maly
-. tiaii mad 1:-■ * will ~
w .W.e to ..,._Ml a ..
U.au oopy for yoa.,
You
-.y give a copy of thi• ~t
to ·azryma ulw:lg for· pzoof of your .U.
•
UH thia lrlll and your -
aactly aa tlley appear at t.ba top cf thia notice on all
your f.-:ral tax foma.
• Refer tQ thi• !ml on your tax-related~ arid ~ta.
If you ~ve qµut1aia about your SDI, you cu call UII at the~ lllllllbll:t' or write to
1111 at. tbla ~
~
at the t.q> ot th1.- noUoe. ·xt you- write, pl.MA tear off ~
atub,
at thii bottolt of ,thia nodc:w IIDd .lililld it alcmg iri.th )'oUr lettet.
U yat do i:lot Diled to
write ua, do not «11pleua and ntum l;be atub.
Your NIM c;ic:atrt!l uaoaiated with thi• Jmf ia XRJM.
You will -1. t:o provide thia
iDto:r,ation, &10119 with yaar SIR, if )'Oil fU.a your retu.rna *ltlCtnlllically.
'ffila)Jc.' you. for Y'0llJ:' ooq)IIX'atiOD.
lfMr) thi• pu:t ror yatt NOOJ!'&I.
CP 575 A (a.,,. 7-2007)
R.et\!ffl thia part wi
0
th 1111)' ~
eo -
aay ldmtify your IICl0CIUDt.
Pl..,._
oo~ any e:tT!>X'II in your ~
or lldlb:-.
CP 575 A
9!1!19!1!19Jlllll
Your Tltlepbooe Nlnber But ,t'iiia to Call llM'S o, THIS lll)'TlCB,
09~01~2018
(
)
~
:nar.tffCATI<:8 IQIBIR,
83-11Jl377
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1,bJJ,1,l,1,J,l.,ld.Jl,.,11_,i,t.,IIJ,1.,I
i'ailN, •. ,
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.iamaa,v D1DOBTRIKS
CARL mll'Mk> ~
Qot.11 MD
3081 ~TIU.
IXltlm.ASVXLta, <a 30135
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 72 of 134

621
1
Q.
Okay.
Now, in terms of once that filing is transmitted to
2
the agency, is the TurboTax system or the EF
the electronic
3
filing engine still kind of monitoring that return, if you
4
will?
5
A.
Yeah.
We -- we constantly check for the acknowledgment
6
from the -- from the IRS for -- for filings.
And they give
7
acknowledgments in batches, large batches of filings.
And
8
we -- we check consistently and those are retrieved from the
9
IRS.
10
Q.
Okay.
Now, what exactly is the acknowledgment that you're
11
looking for?
12
A.
The acknowledgment is going to come back as succeeded,
13
meaning that the return was accepted by the IRS, or rejected,
14
and if it's rejected, it's going to have an error associated
15
with it.
The IRS is going to return a very clear error for
16
what's wrong with it and that will -- those are the two
17
responses.
18
Q.
Okay.
So let's talk about if a return is rejected by the
19
IRS or by an agency.
Would TurboTax relay that information?
20
A.
Yes.
TurboTax, depending on the error from the agency,
21
TurboTax is going to give a response to the customer with the
22
information on how to solve the problem, how to fix the
23
return.
That's -- that's the most common one.
24
The other
the other thing that can happen is there
25
will be an error from the IRS in this case that is unknown,
X JO
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 73 of 134

1
2
Thank you, Your Honor.
There you go .
Thanks.
3
CROSS-EXAMINATION
4
BY MR. FINLAYSON:
654
5
Q.
Good afternoon, Mr . Davis.
Good afternoon.
I just have a
6
few questions for you.
7
MR. FINLAYSON:
This -- if I could see the 220 that 's
8
on the government's computer.
No?
9
I'm sorry .
Madam Clerk, can I get 220 that's on the
10
government's computer.
11
12
13
14
15
MS. CONNORS:
The paralegal table .
COURTROOM DEPUTY:
So it 's at the podium.
MR. FINLAYSON:
Right.
MS. CONNORS:
Oh , sorry.
MR. FINLAYSON:
Thank you.
Wonderful.
16
BY MR . FINLAYSON:
17
Q.
This document we've been talking about for a good while
18
now, that's an Excel spreadsheet, right?
19
A.
Yes.
20
Q.
And did you prepare that document?
21
A.
My team did, yeah.
22
Q.
And so that is the
23
A.
Or part of the team.
24
Q.
Okay.
So it 's a summary of a variety of other
25
right?
Is that fair?
X 11
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
documents,
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 74 of 134

655
1
A.
No, this is data taken right from our databases.
2
Q.
So that -- was this -- was this -- let me ask it this way :
3
Was that automatically generated by your databases?
4
A.
No.
So the data is in the database per the subpoena
5
requirements, we do a search based on what the court's asking
6
us to look for.
And then we search the databases and this was
7
what was returned from those searches.
8
Q.
But was it returned in one single spreadsheet or was it
9
copied over from the individual documents?
10
A.
No.
It was put right into a spreadsheet.
The data pulled
11
from the database and put into a spreadsheet.
12
Q.
And how is it pulled?
Is it copied or is it somehow
13
automatically populated?
14
A.
So it's a -- it's a
it's done by the servers.
It's --
15 it's code that actually talks to the database, makes a request
16
for the data in the database, using a search.
The database
17
responds providing that, that data is stored on a server and
18
then -- and then we pick it up and give it to you, the
19
subpoena request.
20
Q.
There's a whole lot in that.
21
you take me through it.
I'm going to have to help
22
Did you -- so do you have to like build a code to
23
make this spreadsheet happen?
24
A.
That's -- build a code.
Well, everything is built.
I
25
mean , you know, everything's been built to do this, yes.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 75 of 134

656
1
Q.
So is it like SAS or some type of program like that that
2
would --
3
A.
No, it's
it's not.
It's a s ervice.
I'm not a
4
programmer, but it ' s a service des i gned to read the database
5
with a query and have it return the data.
6
Q.
And so that program that some programmer, not you , built
7
i n your office gathered this data s omehow and put it into this
8
Excel spreadsheet?
9
A.
Yeah, I would -- I would say it talks to the database and
10
the database responds , putting that -- putting that data in a
11
spreadsheet form.
12
Q.
Okay.
So nobody went in individually and copied and
13
pasted and copied and pasted?
14
A.
No, it ' s all automated.
And i t' s -- the database is huge ,
15
first of all, so it takes some time to look through the entire
16
database for the query .
17
Q.
Okay.
I think I ' ve got it.
18
And we are looking at I guess it ' s eight entries that
19
are on this spreadsheet?
20
A.
Yes.
21
Q.
And it looks like there were three returns -- three
22
returns that were accepted, five tha t were rejected ; is that
23
right?
24
A.
Yes, that ' s what I see.
25
Q.
Now , you're just on the back end, you're -- you ' re -- you
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 76 of 134

1157
1
Lewis without his knowledge goes to his house, logs in on his
2
TurboTax account and files a tax return because she had to
3
have accessed a file on his computer that had old identity
4
information on it.
5
But ladies and gentlemen, remember the testimony of
6
TurboTax.
They talked about how there were multiple rejected
7
tax filings.
And what happened is that the Social Security
8
number ending in 6010 was the earliest return, the first one,
9
and it gets rejected after it was filed -- attempted on
10
February 6th.
11
But also on February 6th, there was this submission
12
attempt under the other Social Security number, 0540.
And you
13
heard how the error message for both of those returns was that
14
the EIN on the W-2 was a mismatch essentially.
That it was an
15
impossibility that you could have a W-2 from 2020 that had an
16
EIN on it that was not issued until 2021, so they get
17
rejected.
18
And so what happens next?
Another attempt.
Another
19
attempt using another EIN.
This one also doesn't go through,
20
because he's still using one of the EINs for Kremkov that's
21
issued in 2021.
22
And why is he using those two EINs to try to do these
23
tax returns?
Because he knows those two EINs actually have
24
Kremkov Industries associated with them.
25
But when those two fail, the third time is the charm.
1
UNITED STATES DI STRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 77 of 134

1158
1
And he goes back and he is first able to go under that earlier
2
Social Security number, 6010, and he tries it with the 1377
3
EIN number, the one issued in 2018, that's not in the name of
4
Kremkov Industries, it's instead just in the name of Carl D.
5
Torjagbo.
And when that one ends up going through, it's
6
ah-ha, found the right one.
So the next morning, he submits
7
the tax return under 0540, so both of those end up going to
8
the IRS.
9
He now knows 1377, that EIN issued in 2018, is the
10
magic number.
And that's precisely why when May 7th of 2021
11
rolls around, he knows that's the one he's got to use if he
12
wants to try to tell Chase Bank that he was actually in
13
operation before February 15th of 2020.
Shifting information,
14
whatever works, whatever works to get millions of dollars.
15
Ladies and gentlemen, I'll remind you he never paid a
16
dime to Social Security, not in 2020, not under either one of
17
the Social Security numbers.
18
And yet what he wants you to believe is that he told
19
Michael Lee pay my tax withholdings sometime in 2021, early
20
2021.
Ladies and gentlemen, that simply doesn't make sense.
21
When you go to file a tax retu~n at the end of the year, you
22
put in what your earnings are, you put in any withholdings
23
that you have, and if you have losses from a company, you put
24
in your losses, that's how it works.
At the end, then your
25
return is going to say either the IRS owes you money or you
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 78 of 134

647
1
A.
Yes.
2
Q.
Now for Row 7, using Social Security number ending in
3
6010, what is the timestamp?
4
A.
February 12th, 2021, 6:37.
5
Q.
Approximately how much time later?
6
A.
22 minutes.
Yeah.
A little less than 22.
7
Q.
Okay.
And now since this one went -- says succeeded, does
8
that mean no error message?
9
A.
Correct.
It means the federal agency accepted the filing.
10
Q.
Okay.
And does this return list the Houston, Texas,
11
address?
Again, it would be the row in yellow.
12
A.
It does.
13
Q.
And taxpayer date of birth that was transmitted,
14
September 8 of 1975?
15
A.
Correct.
16
MS. CONNORS:
And, Ms. Kelley, if you will put it
17 . back at the paralegal for me.
18
And if you can pull up Government's Exhibit 226,
19
please.
20
BY MS. CONNORS:
21
Q.
Now, Government's Exhibit 226, does this correspond to
22
that Row 7 on the spreadsheet?
23
A.
Can I see the spreadsheet again?
24
Q.
Absolutely.
25
3
MS. CONNORS:
I'm sorry, Ms. Kelley.
Could you
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 79 of 134

501
1
government.
2
Q.
The U.S. federal government?
3
A.
The U.S. federal government.
4
Q.
And were foreign businesses eligible for PPP loans?
5
A.
No.
6
Q.
Would a mining company with all of its employees in Ghana
7
have been eligible for a PPP loan?
8
A.
No.
9
Q.
So you mentioned that speed was an issue.
10
Why was processing these loans quickly important as
11
part of the PPP program?
12
A.
One, it was a mandate by the United States president.
13
And secondly, it was to get the funds directly to the
14
businesses that were in need of getting the funds.
15
Q.
And wheti was the PPP program originally created?
16
A.
On March 2020.
17
Q.
And were there multiple opportunities to get PPP loans?
18
A.
Yes.
19
Q.
When was the second round of the PPP program announced?
20
A.
The second round was December of 2020.
21
Q.
And specifically was the -- was that part of the Economic
22
Aid Act passed by Congress and signed into law in -- on
23
December 27th of 2020?
24
A.
Yes.
25
Q.
During what time period could businesses apply for a
Exh14
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 80 of 134

510
1
A.
It meant that the business had generated revenues.
2
Q.
If a business was operating in Ghana but not operating in
3
the United States , would it have been correct to say that it
4
was in operation for purposes of this form?
5
A.
No.
6
Q.
If a business did not provide documentation showing that
7
it was in operation as of February 15th, 2020 , could it have
8
gotten a PPP loan?
9
A.
No.
10
Q.
Can you please read the second certification on Page 2 .
11
A.
Current economic uncertainty makes this loan request
12
necessary to support the ongoing operations of the applicant.
13
Q.
And why was this certification included?
14
A.
We wanted to make sure that the applicant was currently in
15
operation and they did not have liquidity to support the
16
ongoing operations of the business.
17
Q.
If a company did not have any operations, could the loan
18
have possibly been necessary to support the ongoing operations
19
of the business?
20
A.
No .
21
Q.
If a company was registered in the United States but did
22
not have any U.S. operations, would it have been eligible for
23
a PPP loan?
24
A.
No.
25
Q.
Were there any restrictions on the number of employees
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 81 of 134

513
1
A.
Because that's a part of the eligibility.
2
Q.
And if the answer to that question had been no, could the
3
loan have been approved?
4
A.
It would not have been eligible.
5
Q.
And how was it determined whether the United States was an
6
employee's principal place of residence?
7
A.
It's based on the IRS determination of place of residence.
8
Q.
And if a business had employees in foreign countries,
9
could payments to those employees be counted for purposes of
10
calculating the amount of the PPP loan that the business could
11
receive?
12
A.
No.
13
Q.
Was it enough that a person was a U.S. citizen for that
14
person -- if -- if that person lived in another country, could
15
a U.S. citizen who lived in
who resided ~n other countries
16
payroll be counted in terms of calculating the amount of the
17
loan?
18
A.
Would you repeat the question?
19
Q.
Yes.
Sorry.
That was terrible.
Sorry.
20
All right.
If a person was a U.S. citizen but they
21
22
23
24
25
resided in another country , could their employer
money paid to that employee when calculating the
monthly payroll for purposes of calculating the
PPP loan
A.
No.
they could get?
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
count the
average
size of the
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 82 of 134

514
1
Q.
And why, why not?
2
A.
Because the purpose of the PPP loan was to keep American
3
workers paid.
And the determination for the number of
4
employees was based on a size standard , not to calculate the
5
loan amount.
6
Q.
And what about if an American expat who lived and worked
7
in Ghana but still had a house in the United States , would
8
that person -- would you be allowed -- would a business be
9
allowed to count that person's pay in calculating their
10
average monthly payroll?
11
A.
They would not if they did not meet the IRS standard for
12
principal place of residence .
13
Q.
And if a business used independent contractors , could
14
payments to those contractors be included in the business ' s
15
monthly payroll?
16
A.
No.
Independent contractors were eligible to apply
17
separately.
18
Q.
And what about employees paid in cash under the table ,
19
could they count towards monthly payroll?
20
A.
No.
21
Q.
If a company was registered in the United States but
22
operating solely in another country, would that company be
23
eligible for a PPP loan?
24
A.
No.
25
Q.
Why not?
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 83 of 134

557
1
the proceeds of the loan to start a trucking and logistics
2
company?
3
A.
No.
4
Q.
And one certification above that one, the second one down,
5
can you please read that?
6
A.
Current economic uncertainty makes this loan request
7
necessary to support the ongoing operations of the applicant.
8
Q.
If a company was able to pay its employees $45 million in
9
2020, would that suggest that the loan was necessary to
10
support its ongoing operations?
11
A.
Yes.
12
Q.
It could suggest that?
13
A.
It could.
14
Q.
Okay.
Were the
were the -- were the proceeds of a
15
PPP loan allowed to be used to support non-U.S. operations of
16
a business?
17
A.
No .
18
Q.
If Kremkov Industries did not have any operations in the
19
United States, would it have been important to Chase to know
20
that?
21
A.
Yes.
22
Q.
If Chase had known that Kremkov Industries did not have
23
any operations in the United States, would it have approved
24
the loan?
25
A.
No.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 84 of 134

517
1
A.
No.
2
Q.
If a loan was going to be based on gross income, would
3
that have had to have been reflected on the form?
4
A.
Yes.
5
Q.
In connection with a PPP loan application, did an
6
applicant have to submit any documentation of its payroll?
7
A.
Yes .
8
Q.
If a business submitted tax records in support of its
9
application, did those documents have to have actually been
10
filed with the IRS?
11
A.
Yes.
12
Q.
And if a -- if a business supported documents in support
13
of its application , did those documents have to contain true
14
information?
15
A.
Yes.
16
Q.
Was an applicant allowed to make up information --
17
A.
No .
18
Q.
-- in order to get a PPP loan?
19
A.
No .
20
Q.
Were there requirements for how funds received from a
21
PPP loan had to be used?
22
A.
Yes.
23
Q.
What
what did the proceeds of a PPP loan have to be
24
used for?
25
A.
Payroll, rent , mortgage expense , mortgage inte rest
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 85 of 134

564
1
of tax documents.
Who -- is this the start of where the tax
2
documents begin in this form?
3
A.
Yes.
4
Q.
And who
who submitted these?
5
A.
Karl did.
Karl Delano/Torjagbo.
6
Q.
If the tax documents were -- were -- if tax documents -- I
7
believe you testified earlier that if tax documents were
8
submitted in connection with a PPP loan, those had to have
9
been real tax documents that were filed with the IRS, correct?
10
A.
Yes.
11
Q.
If Chase knew that the tax documents had not actually been
12
filed with the IRS, would it have approved the loan?
13
A.
No.
14
Q.
Was it important that the information in the tax documents
15
was accurate?
16
A.
Yes.
17
Q.
If Chase had known that there was inaccurate information
18
in the tax documents provided for Kremkov Industries and for
19
Mr. Delano, would -- would it have approved the loan?
20
A.
No.
21
Q.
So turning to Page 125, what is this?
22
A.
This is Carl's personal tax return, the 1040 form from
23
2020.
24
Q.
And the name is Carl Torjagbo; is that correct?
25
A.
Yes.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 86 of 134

501
1
government.
2
Q.
The U.S. federal government?
3
A.
The U.S. federal government.
4
Q.
And were foreign businesses eligible for PPP loans?
5
A.
No.
6
Q.
Would a mining company with all of its employees in Ghana
7
have been eligible for a PPP loan?
8
A.
No.
9
Q.
So you mentioned that speed was an issue.
10
Why was processing these loans quickly important as
11
part of the PPP program?
12
A.
One, it was a mandate by the United States president.
13
And secondly, it was to get the funds directly to the
14
businesses that were in need of getting the funds.
15
Q.
And when was the PPP program originally created?
16
A.
On March 2020.
17
Q.
And were there multiple opportunities to get PPP loans?
18
A.
Yes.
19
Q.
When was the second round of the PPP program announced?
20
A.
The second round was December of 2020.
21
Q.
And specifically was the -- was that part of the Economic
22
Aid Act passed by Congress and signed into law in -- on
23
December 27th of 2020?
24
A.
Yes .
25
Q.
During what time period could businesses apply for a
Exh16
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 87 of 134

1
PPP loan during that second round?
2
A.
It was through March of 2021.
3
Q.
And starting in January?
502
4
A.
January -- January 13th.
There was a short period that
5
allowed for smaller businesses to apply for the loan, just a
6
two-day period, a two-day period.
7
Q.
So businesses were eligible to apply starting in January
8
of 2021?
9
A.
Yes.
10
Q.
Was there a high demand for PPP loans?
11
A.
Yes .
12
Q.
Were there more applications for PPP loans than businesses
13
that got PPP loans?
14
A.
Yes.
15
Q.
If a business wanted a PPP loan , who would it apply to for
16
the loan?
17
A.
It would apply to lenders that would approve through t he
18
SBA.
19
Q.
And so what was the lender's role with -- and just to be
20
clear, was the SBA the lender or were there different lenders?
21
A.
SBA was not a direct lender .
22
Q.
So would the lenders be institutions like banks?
23
A.
Yes.
24
Q.
What were -- what was the lender 's role with respect to a
25
given PPP loan?
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 88 of 134

709
1
A.
That is correct.
2
Q.
And since this is a check, would it have had to have been
3
mailed?
4
A.
Yes.
5
Q.
So then would there have been some additional time period
6
for the mailing to occur?
7
A.
There could have been, yes.
8
Q.
And in regards to the amount of the refund check , is it
9
$3,366,240.76?
10
A.
That is correct.
11
Q.
Now, if IRS is going to send out a refund check, does it
12
specifically send out any kind of notice in advance saying
13
we're issuing your check on this date?
We're going to put it
14
in the mail on this date and you will receive it on this date?
15
A.
If it's just a basic refund check, the IRS, they don't
16
send a letter for every refund t hey send out.
17
Q.
And here, even though it was a large refund -- refund
18
amount, is it still a basic Treasury check?
19
A.
It looks -- it appears so, yeah.
20
Q.
And I just wanted to get a bit more specific.
In regards
21
to this check, we've talked about that the stimulus payments
22
were deducted from the full refund amount that was requested
23
on the tax return.
24
Was anything else also deducted from the tax return?
25
A.
I believe there were two offsets .
The taxpayer owed money
xh17
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 89 of 134

710
1
to the Internal Revenue Service for previous tax years, I
2
believe it was either 2013 and '14 or '14 and '1 5 , so it's
3
just standard procedure.
If money is owed t o the IRS, before
4
they send you your refund, they're going to take their money,
5
all right.
And then whatever the remaining amount is what
6
you're entitled to as your refund.
7
So basically it squares out, you no longer have a
8
balance, no penalties, no interest , washed off, remaining
9
amount, that becomes your refund.
10
Q.
Okay.
Now, in here, you've testified that the
11
defendant -- there is no record of any tax withholdings
12
actually being paid to the IRS in 2020?
13
A.
That is correct .
14
Q.
So does that mean that if those back taxes were
15
essentially deducted from the refund, but the refund was not
16
owed to begin with, are the back taxes still owed?
17
A.
The taxes will be owed, yes.
18
Q.
Okay.
19
MS. CONNORS:
And if we could pull up Exhibit 202.
20
BY MS. CONNORS:
21
Q.
And, Mr. Hazel, you ' re familiar with an additional tax
22
return for 2020 filed in the name of Carl Torjagbo?
23
A.
I am, yes.
24
Q.
Now, for this tax return, was there a different
25
Social Security number used?
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 90 of 134

687
1
year.
2
Q.
Now, does the IRS in terms of tax returns rely on
3
information that the individual is putting into the form to
4
process the tax return?
5
A.
So the whole basic tax system, the IRS is trusting that
6
the taxpayer files their return honestly and accurately as
7
possible.
So if there's a return on file, and there's a W-2
8
and those numbers match as close as possible together, the IRS
9
won't -- in most cases won't question it at first and will
10
release the refund, as they know people need their refund.
So
11
they ' re instructed by the federal government to try to get the
12
refunds out as soon as possible, because many people are
13
depending on that.
14
Q.
And if they're owed the money back, then they -- the IRS
15
wants to gets them that money back as quickly as possible?
16
A.
That is correct.
17
Q.
Now, if we can look here at the bottom of that screen, as
18
a result of the figures going into this 1040, was there an
19
amount that was stated for a refund?
20
A.
Yes, it is.
21
Q.
And what was the amount of the refund being requested?
22
A.
The amount listed on line 35A is $3,373,441.
23
Q.
And when IRS is processing this return, is it processing
24
it with the assumption that this is accurate information?
25
A.
That is correct.
Exh18
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 91 of 134

1
this was submitted to Chase Bank on May 7th of 2021?
2
A.
That is correct .
3
Q.
Now, could you say what the -- who is this letter
4
purportedly issued to?
681
5
A.
To Kremkov Industries , Carl Delano Torjagbo, sole member.
6
Q.
And what is the address that is listed on this letter?
7
A.
That would be -- thank you .
Thank you
8
Trail , Douglasville, Georgia , 30135.
9
Q.
Okay.
3081 Leatherleaf
10
MS. CONNORS :
And could we slide over 503 possibly so
11
we could see tha t a little more side by side?
There we go .
12
BY MS. CONNORS :
13
Q.
Okay.
So, Mr . Hazel , what is the employer identification
14
number that is purportedly on this letter?
15
A.
The EIN identification
employer identification number
16
listed on this letter is 83-1821377.
17
Q.
So looking at Exhibit 503 , is that the EIN that' s in the
18
first column?
19
A.
That is correct .
20
Q.
Okay.
And, Mr. Hazel, in regards to 1833 , does IRS ' s
21
system have any information that wo'uld be consistent with a
22
letter being issued with 1377 on it but addressed t o
23
Kremkov Industries, Carl Delano Torjagbo, sole member, at 3081
24
Leatherleaf Trail, Douglasville , Georgia?
25
A.
I could not find any letter .
Exh19
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 92 of 134

1
Q.
That's correct.
2
A.
Yeah.
3
Q.
Do you understand that the name of the street is
4
different?
5
A.
Yes, but ...
1053
6
Q.
It says Leatherly Trail and not Leatherleaf Trail.
7
A.
Yeah.
Yeah, but because the name of the street is
8
different doesn't mean a letter wouldn't come there.
If
9
you -- you know, let's say you -- you are trying to mail
10
something to somebody.
You put in an address and even the ZIP
11
Code is not correct, the post office sometimes figures that
12
out and they'll send it to you so just because the Leatherleaf
13
wasn't
14
Q.
So wait.
I want to make sure that I understand.
15
So you think that the post office pulled the correct
16
address for you and put it on an IRS letter.
Is that what
17
your testimony is?
18
A.
Yeah.
My testimony is whatever was sent to me via the
19
IRS, I received it, even if the spelling of the name was not
20
correct.
21
Q.
So let's point out another thing about this.
22
A.
Um-hmm.
23
Q.
You said how would you be able to make this letter.
24
A.
Um-hmm.
25
Q.
Well, because you probably did receive a letter for 8332
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 93 of 134

-
974
1
people.
2
Q.
And they'll all go down in the hole?
3
A.
Some are underground, some are operated on the surface.
4
Q.
And what -- how do they do the work in these mines?
5
A.
So when they have the area, some use shovels and pickaxe,
6
you know, rudiment tools.
And some also use sophisticated
7
heavy equipment like excavators, dozers and all that to mine.
8
They put it on the equipment that is tilted that they
9
wash, you know, gold is heavy so they put blankets and they
10
wash.
And then the sand goes down and then the gold gets
11
stuck in the blanket.
They remove the blanket, wash in
12
bucket.
Some have big -- you know, big equipment that they
13
wash in so that the gold will settle down.
Then they decant.
14
After they decant, then they use mercury and other
15
chemicals to extract the gold, we call it amalgam.
So after
16
they melt the amalgam and then the mercury get out of the gold
17
and they get the real gold.
18
Q.
And is this all done by hand?
19
A.
Some are done with hands, some are done with equipment.
20
Now the Chinese guys have created a whole lot of sophisticated
21
equipment that they use in the small scale -- originally,
22
small scale was supposed to be using rudimental tools and, you
23
know, and the Ghanaians.
24
But now, there are a lot of invasion of Chinese guys
25
in small-scale mining and they are the guys polluting all the
-
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Exh22
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 94 of 134

967
1
MR. FINLAYSON:
I'm not sure what they prefer.
If
2
they want me to qualify him as an expert, I will do that.
I
3
don't know which they prefer.
I can do either one .
All
4
right.
It's just a question of --
5
THE COURT:
I'm going to let him testify to the very
6
limited things you've said you want, which is that there is a
7
country called Ghana in which there are mines and there are
8
people who work in those mines.
9
MR. FINLAYSON:
And can we talk about how many people
10
he has seen working in those mines?
11
12
13
14
15
well.
16
THE COURT:
Yes.
MR. FINLAYSON:
Thank you.
It will be short.
THE COURT:
Yes, okay.
And then what, and then who?
MR. FINLAYSON:
Tom Thurman.
And he'll be short as
THE COURT:
Okay.
And then I'm going to take a break
17
for our afternoon break.
And then at that point, you can tell
18
me whether he's going to testify and we'll move him up here
19
while the jury is out.
20
21
22
23
24
25
Exh23
MR. FINLAYSON:
Very good.
THE COURT:
All right.
You may bring them in.
MR. FINLAYSON:
Let me go get my witness.
COURTROOM SECURITY OFFICER:
All rise.
(Whereupon, the jurors entered the courtroom.)
THE COURT:
Y'all may be seated.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 95 of 134

977
1
A.
No, I've not heard the name until.
2
Q.
Until
3
A.
Yeah.
4
Q.
he hired you, right?
5
And you've never been to a mine
you never heard of
6
him having -- you've never heard of him and you never heard of
7
him having a mine, right?
8
A.
No.
9
Q.
How much do people who work in Galamsey mines make?
10
A.
In Ghana cities, those who operate excavators, I heard
11
they take 5,000 Ghana cedis a month .
But every day , they give
12
them 500 Ghana cedis for daily keeping .
13
Q.
Okay.
And so sorry.
This is the people working in the
14
mines, they're making -- if I showed you a BBC article that
15
says that a person who works in a Galamsey mine makes about
16
$125 U.S. dollars per week, is that about right?
17
A.
125, if you convert to Ghana cedis -- I don't have my
18
phone here.
19
Q.
I've got a calculator there for you if you need it.
20
A.
Yeah, it is like --
21
Q.
Yeah .
22
A.
1,301.
1,300 pay week could be the guys who wash the
23
sand.
But the excavator operators, I think they should get
24
more than that, because every day, according to what I heard
25
from some of my friends, every day they give them like 500
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 96 of 134

978
1
Ghana cedis, so three days would be like a thousand five, 500,
2
yeah, like a thousand five for daily keeping money alone, that
3
is the excavator operators.
4
Q.
All right.
5
A.
But then those who wash the sand and orpailleurs, they are
6
called orpailleurs , I don't know that much, it's not going to
7
be up to 500 Ghana cedis, but for 1,300 pay week will be
8
small.
9
Q.
And that's -- sorry, that's in Ghana?
10
A.
In Ghana, yes.
11
Q.
So about -- like how much would you say in U. S. dollars is
12
somebody working in one of those mines making?
13
A.
In U.S. dollars, let me go back to the calculator.
14
Q.
Yeah, yeah, please.
15
A.
Let me see.
16
Q.
Well, let me just put it to you this way.
17
18
19
20
$500 .
THE COURT :
Hold on.
Let him do it.
MR. EVERT :
Yeah.
THE WITNESS:
In a month, I will say approximately
21
BY MR . EVERT:
22
Q.
$500 a month?
23
A.
Approximately.
24
Q.
Okay.
And so over the course of a year, about 6,000 U.S.
25
dollars is what somebody who is working in one of those mines
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 97 of 134

703
1
A.
The wage and income transcript is built to report anything
2
listed under the Social Security number, so a 1099, interest,
3
your W-2 withholdings.
Even if you had any gambling winnings,
4 it would be like
under a 1099-G.
If you hit the lottery,
5
went to a casino or whatever and the casino reported it to the
6
IRS, that will al l be listed there.
7
Q.
Okay.
And in terms of --
8
MS. CONNORS:
If we can back out of that.
And if you
9
will scroll to the second page.
10
BY MS. CONNORS:
11
Q.
There's two bold headings for Form 1099-INT again.
Is
12
that reporting the same thing, interest from a bank?
13
A.
That is correct .
14
Q.
And if we move to Page 3, is that just kind of the
15
remainder of that 1099?
16
A.
That is correct.
17
Q.
Now, for -- is this the extent of this transcript in
18
regards to all wage and income for 2020 for looking at the
19
Social Security number ending in 0540?
20
A.
This wage and income transcript reflects all income that
21
was reported to the IRS under that tax ID number.
22
Q.
Now, if a -- if federal tax withholdings had been paid to
23
IRS, would it appear here?
24
A.
Yes, it would.
25
Q.
And in terms of W-2, if the W-2 had been -- had gone
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGI A
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 98 of 134

INOLES86 - 1347540
CURRENT BMF NAMELINE
KREMKOV INDUSTRIES LLC
CARL TORJAGBO SOLE MBR
3081 LEATHERLEAF TRL
DOUGLASVILLE
CURRENT BMF N/C KREM
GA 30 135-8930 819
LOC CODE
58 25
LUC 202144
FILING REQUIREMENTS
FISCAL YEAR MONTH 00
941 - 01
940-1
2290-1
PRI OR FISCAL YEAR MONTH 00
EMPLOYMENT CODE
527 POL ORG CD 0
ESTABLI SHMENT YEAR/MONTH 202101
BOD CODE SB BOD CLIENT CODE G
BMFOLI86-1347540
BMF ACCOUNT SUMMARY
NM CTRL : KREM
UP-CYC : 17
ENT UPDT CY : 202144 ACCT FRZ :
ACCT INFO :
RET
MF MF ACT IDRS FREEZE
MFT
TXPD PLAN
MF ASSESSED
MOD BAL
PST STAT CYC
SC
CODES
TAX MODULE CODES
REQUESTED MODULE DOES NOT
TOTAL ASSESSED BALANCE :
EXIST ON MASTERFILE .
(INCLUDING ACCRUALS)
RETENTION REGISTER (V)
LAST PERI OD SATISFIED (L)
FEDERAL TAX DEPOSI T (F)
ADDITI ONAL ACCOUNT SCREENS AVAILABLE :
PRIOR AUDIT HISTORY (Z) AVAILABLE : N
EXEMPT ORGANIZATION (0) AVAILABLE : N
PAGE 001 OF 001
05/ 05 /2 02 2
►BMFPG 001
Page 1 o f 2
AVAILABLE : N
AVAI LABLE: N
AVAI LABLE : N
Exh27
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 99 of 134

PMFOLD2 861347540 2 020 0001
05-05- 2022
10 :5 8 @MCC
THERE IS NO ACCOUNT ON THE PAYER MASTER FILE FOR
86 - 1347540
05/05/2022
Page 2 o f 2
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 100 of 134

Document Name : ats$idrs
PMFOLD283182137720202101
05-04-2022
12:44 @MCC
THERE IS NO ACCOUNT ON THE PAYER MASTER FILE FOR
83-1821377
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 101 of 134

732
1
withholdings, yes.
2
Q.
And so you went -- how did you search for that?
3
A.
As an IRS employee , I have access to certain applications,
4
and the IRS master file.
And then most times, you use -- you
5
start the search with a tax ID number and the name of the
6
individual or the companies.
7
And you can find different things, was there a tax
8
return filed, was there tax returns received, is -- were there
9
payments made.
And as an IRS employee, like I said, I have
10
access to that.
11
Q.
So that means when somebody makes a payment to the IRS, it
12
needs to be logged in by somebody under the number that links
13
to the payor; is that fair?
14
A.
Right.
The IRS requires -- if you ' re going to make a
15
payment to put your tax ID number on it.
If you just send a
16
check to the IRS, they don't know who it belongs to.
17
Q.
Right.
And there are -- there are multiple ways to make
18
payments to the IRS, right?
19
A.
Yes, there are.
20
Q.
You can wire money, can ' t you?
21
A.
I believe so.
22
Q.
You would have to -- I assume you would have to have the
23
wiring information fo r the IRS for some recipient to take that
24
money, right?
25
A.
I believe so .
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 102 of 134

733
1
Q.
And have you ever seen that in the -- in the -- in your
2
many years, have you seen money wired in?
3
A.
I've seen it electronically transferred over, yes.
4
Q.
And I guess you can write a paper check to the IRS?
5
A.
Right.
And once the IRS receives it, deposits it, makes
6
sure the check is a good check, the taxpayer or the business
7
will get credit for that payment.
8
Q.
And that's -- I gather that's like a line person like a
9
what would you call the person that processes those checks
10
when they come in?
11
A.
I don't know.
I've never processed checks.
12
Q.
So you don't know who does that?
13
A.
Someone in the Internal Revenue Service does, but I don't
14
know their title.
15
Q.
Okay.
And I gather
do you know what the title of the
16
persdn would be that would process the wires that come in?
17
A.
I do not know their title.
18
Q.
Okay.
So let's say hypothetically, if you were working
19
for a U.S.-based company in another country, and you wired in
20
money from Europe or from Africa, that would -- I mean, people
21
do -- you do have people expatriates, people that have to wire
22
money back in t o pay their taxes, right?
23
A.
So you're saying someone making a payment to the IRS?
24
Q.
Correct, from another country.
25
A.
Okay.
UNITED STATES DISTRICT COURT
NORTHERN DI STRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 103 of 134

1
Q.
And that -- I mean , that does happen, right?
2
A.
I believe so .
3
Q.
Okay.
Have you ever seen how that gets logged in?
734
4
A.
I do not.
Once again , I don't process checks or payments .
5
Q.
Okay.
So many businesses and I guess self-employed
6
people , too , they have to file
7
withholding payments , right?
they file quarterly
8
A.
Are you referring to the Form 941?
9
Q.
Not the form itself, just the money.
I'm talking about
10
the actual payments for their own taxes.
11
A.
Correct.
12
Q.
And so they will send either a check or a wire , they'll
13
send that to the IRS in some form?
14
A.
Yes.
15
Q.
Okay.
And that ' s kind of -- agai n , it ' s got to be logged
16
in, right?
17
A.
Yes , it does .
18
Q.
And by -- it needs to be with the right account number.
19
A.
Correct.
20
Q.
Okay .
And you searched many -- you searched all kinds of
21
numbers for Mr . Torjagbo, right?
22
A.
That is correct.
23
Q.
And you're saying you didn ' t find -- you didn ' t find the
24
money being paid in?
25
A.
I didn't find any returns nor any payments made .
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 104 of 134

607
1
one?
2
A.
I don't know.
3
Q.
So you're just sort of looking at internal documents after
4
the fact; is that fair?
5
A.
That's fair.
6
Q.
Okay.
Did you know when this loan was going out?
Did you
7
review it at all?
8
A.
I did not review it at time of originations.
9
Q.
Okay.
We talked about forgiveness a little bit.
10
There was a deadline in the program for when
11
borrowers could ask for forgiveness, right?
12
A.
That is correct.
13
Q.
And letters were sent out to all the borrowers saying,
14
hey, if you want forgiveness, now or never, it's the time to
15
ask; is that right?
16
A.
I'm not specifically aware of the outreach around the
17
communication for that.
I can't -- I can't speak to that.
I
18
wasn't part of that process.
19
Q.
Okay.
But you do know there was a deadline?
20
A.
I am very aware of the deadline, yes.
21
Q.
Okay.
And is it -- were the borrowers told about the
22
deadline?
23
A.
It was part of the note document, so they were told.
24
Q.
Okay.
And if they were told about the deadline, if they
25
opted in for forgiveness, they could, but if they didn't opt
Exh31
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 105 of 134

608
1
in, they had to repay the money?
2
A.
Correct.
3
Q.
Okay.
Have you reviewed the list of employees, the
4
payroll list at all?
5
A.
I have.
6
Q.
Okay.
You've seen the names on that list?
7
A.
I have.
8
Q.
Okay.
Like Charlie Brown?
9
A.
Yes.
10
Q.
Isaac Newton?
11
A.
Yes.
12
Q.
Oliver Twist?
13
A.
Yes.
14
Q.
John Snow?
John Snow?
15
A.
I don't remember that one specifically.
16
Q.
James Brown?
17
A.
Yes.
18
Q.
Nancy Drew?
19
A.
I don't remember that one.
20
Q.
Colin Farrell?
Daniel Glover?
21
A.
I don't remember that one in detail.
22
Q.
Gene Hackman?
23
A.
Yes, I do remember that one.
24
Q.
Bless his soul.
25
A.
Edwin Moses.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 106 of 134

1093
1
Q.
And you didn't disclose to the Social Security
2
Administration that you supposedly had incorrect information
3
on that passport, did you?
4
A.
No, because the only form of identification I had was the
5
passport that I came to the United States with .
6
Q.
So repeatedly in the past, you have been willing to
7
provide false information to the United States government in
8
order to get what you wanted, right?
9
A.
That is incorrect .
That ' s incorrect.
10
Q.
Did you get a visa from the United States?
11
A.
Yes, I got a visa from the United States.
12
Q.
Did you get a Social Security card from the United States?
13
A.
Yes .
14
Q.
And both of those were based on information that you knew
15
were false, right?
16
A.
They were not false.
It was a mistake made on the
17
passport.
18
Q.
But you knew that you were presenting a passport with
19
false information on it, right?
20
A.
I wouldn't say false information, because the fault is not
21
mine.
The fault is either my parents or the people that
22
provided the documentation.
23
Q.
But it's your fault that you were willing to present that
24
to the United States government in order to get what you
25
wanted, right?
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 107 of 134

1095
1
Q.
So again, you're a college graduate, you're a pilot , you
2
can read English , correct?
3
A.
Yes, I can .
4
Q.
And yet, you didn't see that in a form that only has -- it
5
has less than 20 questions on it, you didn ' t see that it
6
indicated, one , have you had another Social Security number
7
assigned before; is that right?
8
A.
Yes, that's right.
I skipped it.
I don't know .
9
Q.
Well, you didn ' t skip it.
What you did was you said no.
10
That is marked on that form.
You said no, never had a
11
Social Security number before , right?
12
A.
Yes.
13
Q.
So you lied to the Social Security Administration to get a
14
second Social Security card, right?
15
A.
I did not lie.
16
Q.
At that point , you're now wanting to change, now you want
17
to be a bit younger, four years younger , so you change -- the
18
date of birth is different, right?
19
A.
Yes.
The date of birth is different, because I explained
20
earlier, I got the birth certificate from Ghana, I presented
21
it to immigration , wrote a letter, explained why, and
22
immigration rectified the error.
I corrected that mistake at
23
the earliest possible time that I could do that .
24
MS. CONNORS:
Let 's pull up Government's Exhibit 7
25
and 9 side by side .
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 108 of 134

fj)Inte1nal Revenue Service
Ur:iterl ~t~ es Dep!lrtm &.-J of [he TreaS\./1"/
T::.
i
1'>
P.roduci:. Contain:,; Se n-siti
ve .
Taxpa • . er.
:Data
Account Transcript
F::nn Nui:,l?cr:
Rsp,n i: f ;.n
Tax .Peri ed Endin,~:
·r-n.~p,lyt~ r. .t-ch1.nti.fica_t.i,~;n
Ntar~er:
Request Date;
Res"j;.tl-rise Date:
·•.rra<;ki.ng Nu;;;ber:
-
Any minus sign shown below signifies a credit amount --
Ac .-~() tir:t. b<: lar:.~:-<:: ~
A,c.:;r~t'd i::te!:·est:
I>.ccrue~l penalty :
Accac;nt. balanc.e plus ace: rual s (:tl1i.s i 5 not a pay9ff
3.::lc,,.mt l:
$Q . ,'.)Q
.SQ . GO
As ot :
$0.00
.u.s of:,
$0,I,lO
Ho lnf:ormation from the return or as adjusted **
.Exetn:r;.-.::.~t C\":~~ :
.F':i _li:1g .~c;~ti.::.s :
Ad:Ju_st~~d ~·l YVss incom~:
'l'axa.l~!r:: i n~c.im~i:
SE tt:x~lblt·: ·in c om~ ~~c:.~ra.ye =·:
SE 1;,,x,~i;,lu i=n ,;cme =iipc-,µr,:;~:
Total sel-f empl oy.m~nt ta·x:
Ret:.::.rn d:.:e cta·te er r-e.t ·u:t ·:n t·~•'.!e.iv~d cl~.te c:~h.iCt:fev-e·r 4s l~te::) :
TRANSACTIONS
COD.E EXPLANA'l'.ION OF TRANSACTION
-------------------------------
150
tax =::,~tu.rn f_il;~d
32221-tSl-354~8-1
80f
~-2 O? 1099 withholdi.ng
766
Ctr:':dit tc yo·ur a·c.c.cunt.
290
Addi=t i.-r.:na l t,1.x. as-si?s ~i<:\d
2bi~4-gg9-0s099-D
971
Noti.ce. i .s=st.ed
NOTIC~l44-'i
841..i
Refund issued
29C
Additi.onal tax assessed
20254-9 99-05055-D
~)'.C;LE
20211.405 0 4- 26-2021
05- 0-4~202.o
20201.60::, 05-04<!020
01-18:-2021
0-1-18.-2i12.l
66-04-·2625
10.81 716·0,4 .. 1 f.i 4
1640
12-:>1-2b:?O
07-04 - 20.-;2
07--04 - 2[•22.
Single
-~~799, 949.,Jb
S(L ·GO
Sb.. GC
et:. =oo
S·C .00
04 - 15..-P,021
·s4 -26-7.G:?.J.
S88 ,.l'H.;l0
- ~-~; ,_ 4.~ 9_, fL~5. CO
-$1,200.00
$1 .. ,200.0G
-$ 6<) 0. 00
$5(10. () Q
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 109 of 134

.CODE EXPLANATION OF TRANSACTION
-
-~Q
20141231
826
~ced ~.t tr·ansferred ou~ to
'30
?1n.::,12.n
971
N;:tice izsvad
CP 0016
971
Notice issu~d
CP 0053
570
Addittc:1~1 accy,~.n t a..:tic,n periO.ini
5"?1
Resc:.l·,1ed <.icltjit:ir.)Jlal a,~cpu_nt pct.ico
960
,b.pr,-,j,nt.ed r-ep;t·eser.1~ati,ye
-1~0
Uncleli.vepeel refund ret;,irn~.d to IRS
7f7
Red.need 9,r ,!:€Hl!.alVed GIE\dit. to your ~!':'.CCUnt
971
Notice iss~ed
CP OC3:.:.
CYCLE
DATE
0-4-15-2021
04-15-2021
O<l -2 6-2(:21
05-0~-2021
06-03-2021
02-14-:2.022
01-1-8-2021
01-1-8-2021
03 - -2·8-2022
SO.OG
$0 .00
$3,3tl6,240.i(;
$0 .0 0
-$(;·00. 0 0
$600.00
$0 . 00
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 110 of 134

fJj Internal Revenue Service
United States Department of the Treasury
This Product Contains Sensitive Taxpayer Data
Account Transcript
Form Number:
Report for Tax Period Ending:
Taxpayer Identification Number:
CARL D TORJAGBO
1855 PIEDMONT RD NE STE 100
MARIETTA
GA
30066-4271-254
Request Date:
Response Da<:e:
Tracking Number:
Account balance:
-Any minus sign shown below signifies a credit amount -
S0.00
Accrued interest:
Accrued penalty:
Account balance plus accruals (this is not a payoff
amount):
$0 . 00
As of:
SO. 00
As of:
$0.00
** Information from the return or as adjusted 0
Exemptions:
Filing status:
RETURN NOT PRESENT FOR TIDS ACCOUNT
TRANSACTIONS
06-16-2025
06-16-2025
108243413749
1040
12-31-2020
592-71-6010
12-05-2022
12-05-2022
co
Single
CODE EXPLANATION OF TRANSACTION
CYCLE DATE
AMOUNT
_______________ ....;;.;;.;. ..
No tax return filed
This Product Contains Sensitive Taxpayer Data
I
l
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 111 of 134

1212
1
one of the individual counts in the indictment.
Okay?
2
So you have to select either guilty or not guilty for
3
each one of the counts at issue .
Okay?
4
You will take it with you.
And when you all have
5
agreed on the verdict, your foreperson will sign it at the end
6
and will date it and will keep it and let us know that you
7
have reached a verdict.
Okay?
8
If you wish to talk with me at any time, I ask that
9
you write a note and you give it to the court security
10
officer, who will give it to me.
I will respond as quickly as
11
possible, either in writing or more likely by bringing you
12
back in here.
13
But I want to caution you not to tell me how many
14
jurors have voted one way or the other if you write a note.
15
Okay?
That is not for me or for anybody else to know.
16
17
Do you understand?
So if you write
if you want to communicate with
18
me, write down your note but don't tell me where you-all are
19
in your deliberations.
20
21
Okay.
Any questions about that?
A little bit more housekeeping.
I believe the
22
downstairs lunchroom closes at 1:30 on Friday, I've been told
23
that.
So why don't you do this, why don't when you get down
24
there -- when you get into the jury room, I'll have you go to
25
lunch immediately.
And then when you come back, you can
Exh35
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 112 of 134

1213
1
select your foreperson.
2
And at that time, after you've selected your
3
foreperson, you can begin your deliberations.
Okay?
4
Wait until you've all got your food together.
And if
5
you want to work over lunch, you can, or you can eat and you
6
can start your deliberations after that.
Okay?
7
It will take us a couple of minutes to get you all of
8
the exhibits back there, so go ahead and get your lunch right
9
away.
Okay?
10
Do y'all bring them back up here when they're
11
deliberating or do they eat down there?
12
COURTROOM SECURITY OFFICER:
Either way.
There's
13
rooms they can go in down there.
14
THE COURT:
Okay .
You can't deliberate down there,
15
you've got to deliberate up here, but y'all can decide what
16
you want to do.
When you're deliberating you all have to be
17
together.
Okay?
18
You can't deliberate where some people are getting
19
lunch or anything like that.
Any questions about that?
20
So go in the back, go have lunch, then come back
21
at that point, select your foreperson and begin your
22
deliberations.
Okay?
23
24
25
Okay?
Yes, one second.
Hold on.
Don't go yet.
One second.
Dean, Ms. Dean, okay, you stay here.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
and
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 113 of 134

686
1
Q.
So that figure is -- there's nothing to suggest that that
2
money was ever paid to IRS?
3
A.
Per my research, I could not find any withholdings listed
4
for the
under that tax ID number for the tax year 2020.
5
Q.
Now, Mr. Hazel, can you explain in terms of tax
6
withholdings, how did -- how does that reflect when you are --
7
well, let me see how should I ask you this.
8
If you have tax withholdings, is that what is going
9
to determine in large measure whether is a potential refund of
10
any taxes paid at the end of the year?
11
A.
Yes, it does.
12
Q.
So how does that work essentially?
13
A.
So on a basic W-2, where you receive your paycheck, like
14
every two weeks, you have your income, what you paid, and your
15
withholdings.
And the withholdings is the credit that you're
16
getting for paying the taxes.
17
At the end of the year, you file Form 1040, right?
18
It's basically a balance sheet of what you did.
You list on
19
the first -- that Line 7 all the income you earned, received,
20
being paid.
21
And there's a chart that says how much tax liability
22
you should have.
If your withholdings is more than your tax
23
liability, you have a surplus, you'll get a refund.
24
If your withholdings is below the amount you should
25
have paid, you may owe the IRS some money at the end of the
Exh36
UNITED STATES DISTRICT COURT
NORTHERN DISTRI CT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 114 of 134

Page 1 of 16
lefile GRAPHIC Drint - DO NOT PROCESS I ORIGINAL DATA - Production I
DLN: 202054858345401
E 1040
DepartmentoflheTreasury-lnlemalRevenueService
(99)
2019
J
.£
U.S. Individual Income Tax Return
0MB No. 1545-0074 IRSUseOnly-Donotwriteorsoapleinlhisspm .
0 Amended Return ~
Single O Married filing jointly O Married filing separately (MFS) 0 Head of Household (HOH) 0 Qualifying widow(er) (QW)
FIiing Status
If you checked the MFS box, enter the name of spouse. If you check the HOH or QW box, enter the child's name if the qualifying
Check only
person Is a child but not your dependent. ►
one box
Your first name and middle initial
Last name
CARL D<TORJAGBO ~
If Joint return, spouse's first name and middle Initial
Last name
Home address (number and street). If you have a P.O. box, see instructions.
I
Apt. no.
3081 Leatherleaf Tri Apt 612
City, town, or post office, state, and ZIP code. If you have a foreign address, also complete spaces below (see instructions).
Douglasville, GA 30135
Foreign country name
I
Foreign province/state/county I
Foreign postal code
Standard
Deduction
Someone can claim: 0 You as a dependent D Your spouse as a dependent
D Spouse itemizes on a separate return or you were a dual-status alien
Your social security number
771-36-0540
Spouse's social security number
Presidential Election Campaign
Check here IT you, or your spouse IT filing
jointly, want $3 to go to this fund.
Checking a box below will not change your
tax or refund.
D You D Spouse
If more than four dependents,
see Instructions and ,/ here ►0
Age/Blindness
You: 0 Were born before January 2, 1955 D Are blind
Spouse: 0 Was born before January 2. 1955 0 Is blind
Dependents (see instructions) :
(2) Social security number
(3) Relationship to you
(4) ,/ if qualifies for (see Instructions):
11) First name
Last name
Child tax credit
Credit for other dependents
D
□
D
l J
D
□
D
□
1
Wages, salaries, tips, etc. Attach Form(s) W-2
1
f!,1
129,000
Standard
2a Tax-exempt interest ,
2a
b Taxable interest. Attach Sch. B ~ required
2b
Deduction for -
• Single or
3a Qualified dividends
3a
b Ordinary dividends. Attach Sch. B ~ required
3b
Married filing
4a IRA distributions
4a
b Taxable amount
4b
separately,
Pensions and annuities
4c
d Taxable amount
4d
$12,200
C
• Married filing
Sa Social security benefits
Sa
b Taxable amount
Sb
jointly or
6
Capital gain or (loss). Attach Schedule D if required . If not required, check here
►□ 6
Qualifying
widow(er),
7a Other income from Schedule 1, line 9
7a
-107,811
$24,400
b Add lines 1, 2b, 3b, 4b, 4d, Sb, 6, and 7a . This is your total income
• Head of
►
7b
21,189
household,
Sa Adjustments to Income from Schedule 1, line 22
Sa
12,915
$18,350
b Subtract line Ba from line 7b. This is your adjusted gross income
►
Sb
8,274
• If you checked -
I
I
any box under
9
Standard deduction or itemized deductions (from Schedule A)
9
12,200
Standard
10
Qualified business income deduction. Attach Form 8995 or Form 8995-A
I 10 I
Deduction, see Ua Add lines 9 and 10
Ua
12,200
Instructions.
b Taxable income. Subtract line 11a from line Bb. If zero or less, enter -0-
Ub
0
For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see separate instructions.
Cat. No. 113206
Form 1040 (2019)
Exh40
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 115 of 134

Page 2 of 16
Form 1040 (2019)
Paoe 2
• If you have a
qualifying
child, attach
Sch. EiC.
• If you have
nontaxable
combat pay,
see
instructions.
Refund
Direct deposit?
See instructions.
Amount
You Owe
Third Party
Designee
(Other than
paid preparer)
Sign Here
Joint return?
See
Instructions.
Keep a copy for
your records,
Paid
Preparer
Use Only
12a Tax (see insl.) Check ff any from Form(s): 1 D 8814 2 04972 30_
12a
b Add Schedule 2, line 3, and line 12a and enter the total
►
12b
13a Child tax credit or credit for other dependents .
l13a l
b Add Schedule 3, line 7, and line 13a and enter the total
►
13b
14
Subtract line 13b from line 12b. If zero or less, enter -0-
14
0
15
Other taxes, Including self-employment tax, from Schedule 2, line 10
16
Add lines 14 and 15. This is your total tax .
►
17
Federal income tax withheld from Forms W-2 and 1099
18
Other payments and refundable credits:
a Earned income credit (EiC) ~
18a
b Additional child tax credit . Attach Schedule 8812
18b
C American opportunity credit from Form 8863, line 8
18c
d Schedule 3, line 14
18d
e Add lines 18a through 18d. These are your total other payments and refundable credits
►
19
Add lines 17 and 18e. These are your total payments
►
20
If line 19 is more than line 16, subt ract line 16 from line 19. This is the amount you overpaid
21a Amount of line 20 you want refunded to you. If Form 8888 is attached, check here
►□
► b Routing number
I
I
► C Type: □checking
D Savings
► d Account number
I
I
22
Amount of line 20 you want applied to your 2020 estimated tax
►
22
23
Amount you owe. Subtract line 19 from line 16. For details on how to pay, see instructions
►
24
Estimated tax penalty (see instructions) •
.
.
.
.
.
•
•
► I 24 I
Do you want to allow another person (other than your paid preparer) to discuss this return with the IRS? See instrucUons.
15
16
17
18e
19
20
21a
23
LJves. Complete below.
~No
Deslgnee's
name ►
Phone
no .
►
Personal identification
number (PIN) ►
Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and belief, they are true,
correct and complete Declaration of preparer (other than taxpayer) Is based on an Information of whidl preparer has any knowledge.
Your signature
Date
Your occupation
lfthe IRS sent you an Identity
******
03-25-2020
Airline Pilot
Protection PIN, enter it here
l
(see inst.)
I
I
r Spouse's signature. If a joint return, both must sign.
Date
Spouse's occupation
lfthc IRS sent your spouse an
ldenlity Protection PfN, enter it here
(see inst.)
I
I
Phone no. (470\ 889-9183
Email address carldelano3@outlook.com
Preparer's name
I
Preparer's signature
I
Date
I
PTIN
Check if:
D 3rd Party Designee
Firm's name
►
I
Phone no.
D Self-employed
Firm's address ►
Firm's EIN ►
Go to www.,rs.gov/Form1040 for Instructions and the latest information.
Form 1040 (2019)
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 116 of 134

Additional Data
Software ID: 19009727
Software Version: ta19mefvl.0
SSN: 771-36-0540
Name: CARL D<TORJAGBO
Top Right Margin - Refund Product Code:
NO FINANCIAL PRODUCT
Header - Primary Name Control: TORJ
Line 18a - Earned Income Credit Eligibility Literal Code:
NO
Page 3 of 16
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 117 of 134

Page 4 of 16
lefile GRAPHIC print - DO NOT PROCESS I ORIGINAL DATA - Production I
DLN:202054858345401
Form2555
Department of the Treasury
Internal Revenue Service
Foreign Earned Income
► Attach to Form 1040 or Form 1040-SR. Complete the Foreign Earned Income Tax
Worksheet In the Instructions for Form 1040 if you enter an amount on lines 45 or 50.
►Goto www.irs.gov/Form25S5 for instructions and the latest information.
For Use b U.S. Citizens and Resident Aliens Onl
0MB No. 1545-0074
2019
Attachment
Sequence No. 34
Name shown on Form 1040 or Form 1040-SR
CARL D TORJAGBO
Your social security number
771-36-0540
Part I
General Information
1 Your foreign address (including country)
353 Itehad Street
2 Your occupation
Airline Pilot
Dubai, UAE
AE
3
Employer's name ► FlyDubai Airlines
4a
Employer's U.S. address ►
b
Employer's foreign address ► 353 Itehad Street
Dubai, UAE
AE
5
Employer is ( check
any that apply) :
a i;zJ A foreign entity
b D A U.S. company
cD Self
d D A foreign affiliate of a U.S. company
e D Other (specify) ►
6a
If you previously filed Form 2555 or Form 2555-EZ, enter the last year you filed the form. ►
2018
b
If you didn't previously file Form 2555 or 2555-EZ to claim either of the exclusions, check here ►
Oand go to line 7.
c
Have you ever revoked either of the exclusions?.
d
If you answered "Yes," enter the type of exclusion and the tax year for which the revocation was effective. ►
7
Of what country are you a citizen/national? ► United Arab Emirates
Ba
Did you maintain a separate foreign residence for your family because of adverse living conditions at your
tax home? See Second foreign household in the instructions .
DYes~No
0YesDNo
b
If "Yes," enter city and country of the separate foreign residence, Also, enter the number of days during your tax year that you
maintained a second household at that address. ►
~9~1 ~~~~~"ri.,a.rI.r.I1?.<>u..9 ~~ :. }?.~ ..
9
List your tax home(s) during your tax year and date(s) established. ► .. ,J,)..Sh<>_r_~l_i_~_., _a_pt5.J~l~g)_!; _l5_1:2,_[)',ll:>a_i : _Q_6; 1.9:. .. ~_()}_15 ...
Next, complete either Part II or Part III. If an item doesn't apply, enter "NA." If you don't give
the information asked for, any exclusion or deduction you claim may be disallowed.
Part II
Taxpayers Qualifying Under Bona Fide Residence Test (see instructions)
10
Date bona fide residence began ► ..
.. , and ended ► ....
11
Kind of living quarters in foreign country ► a O
Purchased house
b O
Rented house or apartment
c O
Rented room
d O
Quarters furnished by employer
12a
Did any of your family live with you abroad during any part of the tax year? .
0 Yes O No
b
If "Yes," who and for what period? ►
13a
Have you submitted a statement to the authorities of the foreign country where you claim bona fide
residence that you aren't a resident of that country? See Instructions .
0 Yes O No
b
Are you required to pay income tax to the country where you claim bona fide residence? See instructions .
O Yes O No
If you answered "Yes" to 13a and "No" to 13b, you don't qualify as a bona fide resident. Don't complete
the rest of this part.
14
If you were present in the United States or its possessions during the tax year, complete columns (a)- (d) below. Don't include the
income from column (d) in Part IV, but report it on Form 1040 or Form 1040-SR.
(a) Date
( b) Date left ( c) Number of (d) Income earned in U.S.
(a) Date
( b) Date left ( c) Number of
arrived in
U.S.
days in U.S. on
on business ( attach
arrived in
U.S.
days in U.S. on
U.S.
business
computation)
U.S.
business
15a List any contractual terms or other conditions relating to the length of your employment abroad. ►
b
Enter the type of visa under which you entered the foreign country. ► ..
c
Did your visa limit the length of your stay or employment in a foreign country? If "Yes, " attach explanation .
d
Did you maintain a home in the United States while living abroad? .
(d) I ncome earned in U.S.
on business (attach
computation)
0Yes 0No
DYes D No
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 118 of 134

e
If "Yes," enter address of your home, whether it was rented, the names of the occupants, and their relationship
to
OU. ►
For Paperwork Reduction Act Notice, see the Form 1040 or Form 1040-SR Instructions.
Cat. No. 11900P
Page 5 of 16
Form 2555 (2019)
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 119 of 134

Page 6 of 16
Form 2555 (2019)
Pa e 2
Part III
Taxpayers Qualifying Under Physical Presence Test (see instructions)
16
The physical presence test is based on the 12-month period from ► 06-10-2016.......................
. ....... through ► g}.: .. 9..1.:. .. ?.~_?g ... .
17
Enter your principal country of employment during your tax year. ► Unlted._Arab _Emirates ___ .
18
If you traveled abroad during the 12-month period entered on line 16, complete columns (a)·(f) below. Exclude travel between foreign
countries that didn't involve travel on or over international waters, or in or over the United States, for 24 hours or more. If you have no
travel to report during the period, enter "Physically present in a foreign country or countries for the entire 12-month period." Don't
include the income from column (f) below in Part IV, but report it on Form 1040 or Form 1040-SR.
(a) Name of country
(b) Date arrived
( c) Date left
(d) Full days
(e) Number of
(f) Income earned in U.S.
(including U.S.)
present in
days in U.S.
on business ( attach
country
on business
computation)
~
Part IV
All Taxpayers
Note: Enter on lines 19 through 23 all income, including noncash income, you earned and actually or constructively received during your 2019 tax
year for services you performed in a foreign country. If any of the foreign earned income received this tax year was earned in a prior tax year, or will
be earned In a later tax year (such as a bonus), see the Instructions. Don't include income from fine 14, column (d) , or fine 18, column (f) . Report
amounts in U.S. dollars, using the exchange rates in effect when you actually or constructively received the income.
If you are a cash basis taxpayer, report on Form 1040 or Form 1040-SR all Income you received in 2019, no matter when you
performed the service.
2019 Foreign Earned Income
19
Total wages, salaries, bonuses, commissions, etc .
20
Allowable share of income for personal services performed (see instructions):
a
In a business (including farming) or profession .
b
In a partnership. List partnership's name and address and type of income. ►
21
Noncash income (market value of property or facilities furnished by employer-attach statement
showing how it was determined):
a
Home (lodging).
b
Meals.
c
Car.
d
Other property or facilities. List type and amount. ►
22
Allowances, reimbursements, or expenses paid on your behalf for services you performed :
a
Cost of living and overseas differential.
b
Family.
c
Education .
d
Home leave .
e
Quarters.
For any other purpose. List type and amount. ► ..
g
Add lines 22a through 22f.
22a
35,000
22b
15,000
22c
15,000
22d
22e
22f
23
other foreign earned income. List type and amount. ►
24
25
26
Add lines 19 through 21d, line 22g, and line 23 .
Total amount of meals and lodging Included on line 24 that Is excludable (see Instructions)
Subtract line 25 from line 24. Enter the result here and on line 27 on page 3. This is your 2019
foreign earned Income.
►
Amount
(in U.S. dollars}
19
129,000
20a
20b
21a
21b
21c
21d
22g
65,000
23
24
194,000
25
26
194,000
Form 2555 (2019)
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 120 of 134

Form 2555 (2019)
Part V
All Taxpayers
27
Enter the amount from line 26.
Are you claiming the housing exclusion or housing deduction?
i;zJ Yes. Complete Part VI.
□
No. Go to Part VII.
Part VI
Taxpayers Claiming the Housing Exclusion and/or Deduction
28
29a
b
30
31
32
33
34
35
36
Qualified housing expenses for the tax year (see instructions) .
Enter location where housing expenses incurred (see instructions) ►
Shoreline Apts Building 15 Apt
.6..1.:2. .. P..u..~~-i, . .lJ.~l=. .. ~f: .. ,Q.O.Q.O.Q ··•······
Enter limit on housing expenses (see instructions) .
Enter the smaller of line 28 or line 29b.
r
3~ r
Number of days in your qualifying period that fall within
your 2019 tax year (see instructions).
365 days
Multiply $46.42 by the number of days on line 31. If 365 Is entered on line 31, enter $16,944 here
Subtract line 32 from line 30. If the result is zero or less, don't complete the rest of this part or any
of Part IX .
Enter employer-provided amounts (see instructions).
I 34 I
25,00(
Divide line 34 by line 27. Enter the result as a decimal (rounded to at least three places), but don't
enter more than "1.000" .
Housing exclusion. Multiply line 33 by line 35. Enter the result but don't enter more than the
amount on line 34. Also, complete Part VIII .
►
Note: The housing deduction is figured in Part IX. If you choose to claim the foreign earned income
exclusion, complete Parts VII and VIII before Part IX.
Part VII
Taxpayers Claiming the Foreign Earned Income Exclusion
37
Maximum foreign earned income exclusion. Enter $105,900 .
38 •
If you completed Part VI, enter the number from line 31. }
• All others, enter the number of days in your qualifying
period that fall within your 2019 tax year (see the
38
365 days
instructions for line 31).
39 •
If line 38 and the number of days in your 2019 tax year (usually 365) are the same, enter
}
"1.000."
• Otherwise, divide line 38 by the number of days in your 2019 tax year and enter the result as a
decimal (rounded to at least three places).
40
Multiply line 37 by line 39 .
41
Subtract line 36 from line 27 .
42
Foreign earned Income exclusion. Enter the smaller of line 40 or line 41. Also, complete Part VIII ►
27
28
29b
30
32
33
35
36
37
39
40
41
42
Part VIII
Taxpayers Claiming the Housing Exclusion, Foreign Earned Income Exclusion, or Both
43
Add lines 36 and 42 .
43
44
Deductions allowed in figuring your adjusted gross income (Form 1040 or Form 1040-SR, line 8)
that are allocable to the excluded income. See instructions and attach computation .
44
45
Subtract line 44 from line 43. Enter the result here and in parentheses on Scheedule 1 (Form
1040 or Form 1040-SR), line 21. Next to the amount, enter "Form 255 5. " On Schedule 1 (Form
1040 or Form 1040-SR), subtract this amount from your additional income to arrive at the amount
reported on Schedule 1 (Form 1040 or Form 1040-SR), line 22.
45
Page 7 of 16
Pa e 3
194,000
59,000
31,770
31,770
16,944
14,826
0.12887
1,911
1.00000
105,900
192,089
105,900
107,811
107,811
Part IX
Taxpayers Claiming the Housing Deduction - Complete this part only If (a} line 33 is more than line 36 and
(b} line 27 is more than line 43.
46
Subtract line 36 from line 33 .
46
12,915
47
Subtract line 43 from line 27 .
47
86,189
48
Enter the smaller of line 46 or line 47 .
48
12,915
Note: If line 47 is more than line 48 and you couldn't deduct all of your 2018 housing deduction
because of the 2018 limit, use the Housing Deduction Carryover Worksheet in the instructions to
figure the amount to enter on line 49. Otherwise, go to line 50.
49
Housing deduction carryover from 2018 (from the Housing Deduction Carryover Worksheet in the
instructions) .
49
50
Housing deduction. Add lines 48 and 49. Enter the total here and on Schedule 1 (Form 1040 or
Form 1040-SR) to the left of line 36. Next to the amount on Schedule 1 (Form 1040 or Form 1040-
SR), enter "Form 2555." Add it to the total adiustments to income reported on line 36.
►
50
12,915
Form 2555 (2019)
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 121 of 134

Additional Data
Software ID: 19009727
Software Version: ta19mefvl.0
SSN : 771-36-0540
Name: CARL D<TORJAGBO
PHYSICALLY PRESENT IN A FOREIGN COUNTRY OR
Line 18a(1) - No Travel Explanation Code: COUNTRIES FOR THE ENTIRE 12-MONTH PERIOD
Page 8 of 16
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 122 of 134

lefile GRAPHIC print - DO NOT PROCESS I ORIGINAL DATA - Production I
TY 2019 FEC Record
Name: CARL D<TORJAGBO
SSN: 771-36-0540
Software ID: 19009727
Software Version: ta19mefvl.O
Employee TIN: 771-36-0540
Employee Name Control: TORJ
Employee Name: Carl D Torjagbo
Employee In Care of Name:
Employee Address: 3081 Leatherleaf Tri Apt 612
Douglasville, GA, 30135
Work Performed Residing in US
Indicator:
l;?J
Foreign Employer Business FlyDubai Airlines
Name:
Employer In Care of Name:
Foreign Employer Address: 353 Itehad Street
Dubai, UAE,
, AE
Foreign Employer EIN: 00670012
Foreign Employer Compensation
Amt: 129,000
Foreign Pension Received Amt:
Foreign Pension Taxable Amt:
Page 9 of 16
DLN:202054858345401
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 123 of 134

lefile GRAPHIC print - DO NOT PROCESS I ORIGINAL DATA - Production I
TY 2019 Other Adjustments Statement
...
FORM 2555
Name: CARL D<TORJAGBO
SSN: 771-36-0540
Software ID: 19009727
Software Version: ta19mefvl.0
Other Adjustments Code Text
Page 10 of 16
DLN:202054858345401
.
Other Adjustments Amount
12,915
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 124 of 134

lefile GRAPHIC print - DO NOT PROCESS I ORIGINAL DATA - Production I
TY 2019 Other Income Type Statement
FORM 2555
Name: CARL D<TORJAGBO
SSN: 771-36-0540
Software ID: 19009727
Software Version: ta19mefvl.O
Other Income Literal or Code
Page 11 of 16
DLN:202054858345401
-
Other Income Amt
-107,811
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 125 of 134

lefile GRAPHIC print - DO NOT PROCESS I ORIGINAL DATA - Production I
SCHEDULE 1
(Fonn 1040 or 1040-SR)
Department of the Treasury
Internal Revenue Service
Additional Income and Adjustments to Income
► Attach to Form 1040 or 1040-SR.
li>Go to www.irs.gov/Form1.040 for instructions and the latest Information.
Page 12 of 16
DLN:202054858345401
0MB No. 1545•0074
2019
Attachment
Sequence No. 01
Name(s) shown on Form 1040 or 1040-SR
Ivour social security number
CARL D<TORJAGBO
771•36·0540
At any time during 2019, did you receive, sell, send, exchange, or otherwise acquire any financial interest in any
virtual currency during the year? .
D Yes
~
No
Part I
Additional Income
1
Taxable refunds, credits, or offsets of state and local income taxes
2a Alimony received
b Date of original divorce or separation agreement (see i n structions) ►----
3
Business income or (loss). Attach Schedule C
4
Other gains or (losses). Attach Form 4797
5
Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E
6
Farm income or (loss). Attach Schedule F
7
Unemployment compensation
8
Other income. List type and amoun t ► .t!J···-········-·················-·············-····· .. ··--------
···-·············--··········-·····"·-················-··----··-······-·······-·······-·······-······--··--·····---···-··················
9
Combine lines 1 through 8. Enter here and on Form 1040 or 1040·SR, line 7a
Part II
Adjustments to Income
10
Educator expenses
11
Certain business expenses of reservists, performing artists, and fee-basis government officials. Attach
Form 2106
12
Health savings account deduction. Attach Form 8889
13
Moving expenses for members of the Armed Forces. Attach Form 3903
14
Deductible part of self-employment tax. Attach Schedule SE
15
Self-employed SEP, SIMPLE, and qualified plans
16
Self-employed health Insurance deduction
17
Penalty on early withdrawal of savings
18a Alimony paid
b Recipient's SSN
►
C Date of original divorce or separation agreement (see instructions ) ► ..............
····------
19
IRA Deduction
20
Student loan interest deduction
21
Tuition and fees. Attach Form 8917
22
Add lines 10 through 21. These are your adjustments to Income. Enter here and on Form 1040 or
1040-SR line Ba ..l"f§
. . , . . . . , . , . . . . , . . , . , . . . .
1
2a
3
4
5
6
7
8
·107,811
9
·107,811
10
11
12
13
14
15
16
17
18a
19
20
21
22
12,915
For Paperwork Reduction Act Notice, see your tax return Instructions.
Cat. No. 71479F
Schedule 1 (Form 1040 or 1040-SR) 2019
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 126 of 134

Additional Data
Software ID: 19009727
Software Version: ta19mefvl.0
SSN: 771-36-0540
Name: CARL D<TORJAGBO
Line 22 - Other Adjustments Total Amount: 12,915
Page 13 of 16
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 127 of 134

lefile GRAPHIC print• DO NOT PROCESS I ORIGINAL DATA• Production I
TY 2019 Wages Not Shown Schedule
FEC
Name: CARL D<TORJAGBO
SSN: 771-36-0540
Software ID: 19009727
Software Version: ta19mefvl.0
Wages literal
--
-
Page 14 of 16
DLN:202054858345401
Wages amount
129,000
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 128 of 134

Page 15 of 16
letile GRAPHIC print - DO NOT PROCESS I Production I
DLN: 20205485834540 1
AVS Data - Get PTC Info Res onse
There is no AVS PTC Response for this submission.
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 129 of 134

rag~ 10 Ul J O
lefile GRAPHIC print - DO NOT PROCESS I Production I
DLN:202054858345401
Return Index - sorted by Display Name in ascending order
Display Name
Identifying #
Attach To
Document Type
Regulation
1040
Form
2555
1040
Form
AVS Data PTC Info
AVSDataPTCinfo
FEC Record
1040
Attachment
Other Adjustments Statement
Schedule 1 (1040)
Statement
Other I ncome Type Statement
Schedule 1 ( 1040)
Statement
Schedule 1 (1040)
1040
Schedule
Wages Not Shown Schedule
1040
Schedule
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 130 of 134

1228
1
COURTROOM DEPUTY:
Give me one second.
I have it .
2
Sentencing is set for November 3rd at 10 : 00.
3
THE COURT :
Okay.
Anything else that y ' all want to
4
talk about?
5
6
7
8
MR. FINLAYSON:
No.
No, sir.
MS. CONNORS:
No, Your Honor.
THE COURT:
Okay.
We are then in recess.
I'm going to go talk to the jury .
You-all don't want
9
to talk to the jury?
10
11
MS . CONNORS :
I usually don ' t.
THE COURT :
I think usually the person who prevaiis
12
does not, but ...
13
MS. CONNORS:
Well, I never want to hear something
14
that I don't want to hear.
15
MR. FINLAYSON:
I guess I would ask for --
16
sometimes -- I've run into them in the parking lot before
17
after a trial.
Is it okay to talk to them if they want to
18
talk to me?
19
20
THE COURT:
Yes, totally fine.
All right.
Thank you so much.
I thought that this
21
was a pleasant trial and I appreciate you-all working on it.
22
And we're in recess.
23
24
25
E~47
MR. FINLAYSON :
Thank you, sir.
Thank you.
(Whereupon, the proceedings were adjourned at 2:26
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 131 of 134

E:/Add%20Doc%202255/101 .p<lf
30111 LR,\.THRRLR..o\11 TRL, DO'UGLASVIl.LE, GA, 30135
A-.eMaad,ly
x2.5+BIDl.(DoNGtlDcladeNl/f
$3,&21, 770.00
ED:.JL.UV-)..-I.-~ $!>,554,425.00
Nlallberof_..,._
4!13
PayNl1:
A8-II:
'
la P:a.yroll Com
Iii Rent I Mortgage
£ii Utilities
la Co........d Opemi,,ns
Iater ... t
Expenditures
Pmpc,-Dltllllllml
(aeleclalllllat
la Cavered Property
D C°'"....-ed Supplier
Q Covered Wod:er
D Other ( explain):
llfPly)!
Dam;oge
Com
Protl!dion
Expenditures
Applicalll Ownenhip
List all OWlll!B of20% or more of the equity of the Applic.mt. Atb.ch 2 5epante 5heet iflll!Ce'531)'.
0-,Namc
Tido
CARL TORlAGBO
301111.J!ATHl!RLRAF TRI., DOUGLASVILLE,
GA, 30135
Ifqµn(iw fl l, a> (5) or (6) arc ilWlmd uy§ n 11,g 1g.m will .pot"" apqrop,d
I
Qaellim
y.,
No
I.
b the Appticmt or my OMl.l!I oflhe .Appliaat pre5mtly smpended, clebanecl. prapo!led foe debll!lllfllt, d!dared ille~ rohmtmily
oxduded framparticipaliml in 1hi! 1wl!actioll.by myFedenl department or a_gyq, orpre!<E!lllly ilnaJh-ed iD mybanbuptcy7
□
li2)
li2)
1..
Has lb.1u \ppliamt, myaw.n.er oflhe.Appliamt, or my business O\\Mdorcomrolled by ,myoflhem, nwobomied • direct ar _guauuteed lom D
from SBA or my other Fedenl a:ecyt!Wis{a) curremly ddinqlll!lll, or {b) bu dmalted in the wt7yem mdcausedalou to the
~-"""""'1l?
3.
Is tMAppticmt or my OMl.l!I ot·lhe.Appliaat an owner ohny oth!r bmin.eos, or ba.e cammm, m11111i,'lllenl (iDdudil,g ■ management
~eemml) witll ,my alba: llasine.-.1 If yes, list all such~• (indudin_g lbeir llN• if ,.,."ailable) and de5aibe Ille relalicm5lrip OD a
,..,.m,, wet identified as addmdmnk
4.
Did dM! Appliclllt reci,n,-e an SBA Eccmamic ~
Disaster Loa betwe!!ll Jamwy 31, 2020 111d April J , 20207 If ye,, pro,,ide dmih on a
,..,arm !beet idemified as addellldum B.
□
□
5.
Is the.Appticmt(ifmindi-.idaal) or ,myindi\.idualowning 20% or mare oflbe equity of the Applic111tpre,mly illaroonledor, for my
D
lialoay, presemly !illbject to a:a. indidmenl, crimim.1 infim:mtian, maignment, or otber mum 11)• wllich furmaJ criminal dmge, me brought in
my jurudi<lim,_7 __
_
CT
Initial bere to caatlrm your n,,pallSI! lo q,J!!llian5->
6.
Withia.llM! 1Bt5 yeu.s, fnr m y .li!kmy im<lkmg frmd, bnl>ery, mibemmieat, oca wl• !Welllellt in alaD lpplialion or mapplic.Uianfilr
liederdfinancial imistance, orwi1!iin.dle wt}._, formyotherfi!lony, bas lhe.Appliamt (ifm indn,idual) or 111yatmerofdle Applic.am I)
beencam,i Cll!d;. l)plelJI!~~ 3) pleadednolo cll!ll!lldere; ar4)cammenced 111y liarm ofpuole ocprobatian (iDduding probation before
judgmmf}?
CT
laitial bere Ill caa1irm }"INf n,,pa11S1! 111 ~
6->
7.
Is tM United SU.testheprindplipbce ofreidence foull emplayees illduded:iJI the Applicant's payroll calculstion abo\,.?
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h tMApptic tafnmdlise?
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h ?Mmmchise ti'1l!d in dM! SBA'•-Ftanchi!:e D.iJ.Kt«y?If}'"", enter the SBA Fl:mcbiseldi!lltifierCooe bere:
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101
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Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 132 of 134

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ll * I
Scott Acken
Check Num. fours/Qty.
Gross.
FedTax
SSTaa
MedTax
SIT
oth..- Tax I Ded.
Net Pay
RCA
AJTA
SUI
02/1-412020
1420
80.27
4013.50
-631.86
-248.84
-63.20
-258.18
-245.41
2573.01
307.04
0.00
40.16
02/28/2020
1ll13
80.02
4001.00
-628.95
-248.06
~8.01
-255..34
-245.03
25C5.61
306.07
0.00
0.00
Employee Tolals:
160.29
8014.50
-1260.81
-496.90
-116.21
-011.5.2
-490.44
5138.62
613.11
0.00
40.16
Eli Ackporhor
Check Num. fours/Qty.
Gross
Fed'Tax
SSTaa
Med'Tax
SIT
oth..-Tax I Ded.
Net Pay
RCA
AJTA
SUI
02/1-4/2020
1122
80.21
4010.50
-314.92
-248.65
-68.15
-199.83
-290.37
2898.58
306.80
0.00
40.26
02/28/2020
1615
80.11
4005.50
-314.34
-248.34
-63.08
-199..51
-290.19
2895.04
306.42
0.00
0.00
Employee Totals:
160.32
8016.00
-629.26
-496.99
-116.23
-399..34
-580.5C
5793.62
613.22
0.00
40.26
Augustine Adade
Check Num. fours/Qty.
Gross
'FedTax
SSTaa
MedTax
SIT
oth..- Tax I Ded.
Net Pay
RCA
AJTA
SUI
02/1-412020
1023
86.55
4042.13
-619:12
-250.61
-58.61
0.00
-302.11
2811.68
309.22
0.00
38.99
02/28/2020
1516
86.55
4042.13
-619.12
-250.61
~8.61
0.00
-302.11
2811.68
309.22
0.00
0.00
Employee Totals:
173.10
8084.26
-1238 . 24
-o01.22
-117.22
0.00
-604.22
5623.36
61&.44
0.00
38.99
Luke Addison
Check Num. fours/Qty.
Gross
FedTax
SSTaa
MedTax
SIT
oth..- Tax I Ded.
Net Pay
RCA
AJTA
SUI
02/1-412020
1298
86.18
4017.15
-337.94
-249.06
-63.25
-151.87
-270.51
2.949.52
307.31
0.00
42.82
02/28/2020
1791
86.01
4005.68
-338.61
-248.35
-58.08
-151..33
-270.17
21141.14
306.43
0.00
0.00
Employee Tolals:
1n.19
8022.83
-674.55
-497.41
-116.33
-303.20
-540.68
5890.66
611.74
0.00
42.82
Patrick Agyeman
Check Num. iours/Qty.
Gross
FedTax
SSTaa
Med'Tax
SIT
oth..- Tax I Ded.
Net Pay
RCA
AJTA
SUI
02/1-412020
1373
84.34
3892.95
-341.00
-241.36
-'56.45
-150.00
-261.25
2842.89
297.81
0.00
39.34
02/28/2020
1866
86.01
4005.68
-354.05
-248.35
-63.08
-155.00
-265.20
2925.00
306.43
0.00
0.00
Employee Tolals:
170.35
7898.63
-695.05
-489.71
-114.53
-305.00
-526.45
5767.89
604.24
0.00
39.34
RamunAhmad
Check Num. fours/Qty.
Gross
FedTax
SSTa:a
MedTax
SIT
oth..- Tax I Ded.
Net Pay
RCA
AJTA
SUI
02/1-412020
1387
85.59
3977.33
-353.15
-246.59
~Hf1
-224.53
-269.32
2826.07
304.26
0.00
40.92
02/28/2020
1880
86.02
4006.35
-357.65
-248.39
-58.0Q
-226..55
-270.19
2845.48
306.48
0.00
0.00
Employee Totals:
171.61
71183.68
-710.80
-494.Q8
SBf~~f451 .08
-530.51
5671.55
610.74
0.00
1W2
Page:
2/71
Kaledri Akator
Check N ...... iours/Qty.
Gross
IFedTax
SSTax
Med'Tax
SIT
oth..- Tax I Ded.
Net Pay
FICA
AJTA
SUI
02/1-4/2020
1241
80.12
4006.00
-590.42
-248.37
~8.09
-179.00
-270.18
2659.94
306.46
0.00
40.07
02/28/2020
1734
80.03
4001.50
-589.37
-248,09
-63.02
-178.00
-270.05
2657.117
306.11
0.00
0.00
Employe" Totals:
160.15
8007.50
-1179.79
-496.46
-116.11
-357.00
-540.23
5317.91
1112.57
0.00
40.07
Bruce Akli
Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 133 of 134

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Case 1:22-cr-00171-MLB-RDC Document 259-1 Filed 01/27/26 Page 134 of 134

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