Superseding Indictment as to Leon Haynes (1) counts 1s-26s — United States v. Haynes (Dkt. 54, D.N.J. No. 2:24-cr-00232)

Record facts

U.S. District Court for the District of New Jersey · No. 2:24-cr-00232-WJM · Doc. 54 · 2025-07-22 · Docket on CourtListener

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2021R01118/FMC/SB 
UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
UNITED STATES OF AMERICA 
     V. 
LEON HAYNES 
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Hon. William J. Martini 
Crim. No. 24-232 
Counts 1-18 
26 U.S.C. § 7206(2) 
(False Tax Returns) 
Count 19-22 
18 U.S.C. § 1341 
(Mail Fraud) 
Count 23 
18 U.S.C. § 1028A 
18 U.S.C. § 2 
(Aggravated Identity Theft) 
Count 24 
18 U.S.C. § 1341 
(Mail Fraud) 
Counts 25-26 
26 U.S.C. § 7201 
(Tax Evasion) 
I N D I C T M E N T 
1.
The Grand Jury in and for the District of New Jersey, sitting at
Newark charges as follows: 
Introduction 
2.
From in or around November 2020 through in or around May 2023,
Defendant Leon Haynes (“HAYNES”), a tax preparer, executed a scheme to defraud 
the United States of more than $150,000,000 by preparing and filing more than 
SUPERSEDING
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1,600 quarterly employment tax returns for himself and his clients that falsely 
claimed he and his clients were entitled to receive tax refunds based on 
fraudulently claimed COVID-related tax credits.  
General Allegations 
 
3. 
At all times relevant to this Indictment: 
 
A. 
The Internal Revenue Service (“IRS”) was an agency of the 
United States Department of the Treasury responsible for administering the tax 
laws of the United States and collecting taxes owed to the United States, including 
income and employment taxes.  
B. 
Federal law required employers to collect, truthfully account for, 
and pay over to the United States, certain payroll taxes, including their employees’ 
withheld federal income taxes, Social Security and Medicare taxes, and the 
employer’s matching portion of the Social Security and Medicare taxes.  A 
responsible person at a business was required to file quarterly an Employer’s 
Quarterly Federal Tax Return, Form 941 (“Form 941”), reporting certain 
information and assessing payroll taxes for the business.  On the Form 941, the 
responsible person was required to supply the IRS with information about the 
number of employees the business had and the wages paid by the business during 
that quarter, among other information.  
C. 
An E-File Declaration for Employment Tax returns, Form 8453-
EMP (“Form 8453-EMP”), was a form used to authenticate an electronic 
employment tax return, authorize an electronic return originator or an intermediate 
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service provider to transmit an electronic employment tax return via a third party, 
and authorize an electronic funds withdrawal for payment of federal taxes owed.  
The Form 8453-EMP was required to be signed by an authorized individual of the 
taxpayer business who, in so doing, swore under penalty of perjury that the tax 
return was true, correct, and complete and consented to the electronic return 
originator or intermediate service provider submitting the employment tax return 
to the IRS.  
D. 
A Wage and Tax Statement, Form W-2 (“Form W-2”), reported 
wages paid by an employer to an employee and taxes withheld from those wages.  It 
was issued by U.S. employers to employees and filed by employers with the Social 
Security Administration (“SSA”).  
E. 
IRS Form 1040, U.S. Individual Income Tax Return, is used by 
U.S. taxpayers to file an annual income tax return.  
COVID-Related Tax Credits 
4. 
The Coronavirus Aid, Relief, and Economic Security Act or CARES Act, 
enacted on March 27, 2020, provided for an employee retention credit (“ERC”), 
designed to encourage businesses to retain employees on their payroll during the 
COVID-19 pandemic.  The Taxpayer Certainty and Disaster Tax Relief Act of 2020 
and the American Rescue Plan Act modified and extended the ERC. 
5. 
For calendar year 2020, the ERC was a refundable tax credit against 
certain employment taxes equal to 50 percent of up to $10,000 of qualified wages an 
eligible employer paid to each employee from March 13, 2020 through December 31, 
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2020.  For calendar year 2021, the ERC was a refundable tax credit against certain 
employment taxes equal to 70 percent of up to $10,000 of qualified wages an eligible 
employer paid to each employee during each quarter.  Thus, the ERC was capped at 
$5,000 per employee for calendar year 2020 and $7,000 per employee per quarter for 
calendar year 2021.  
6. 
Generally, businesses and tax-exempt organizations that qualified for 
the ERC were those that: (a) were shut down during 2020 or the first three calendar 
quarters of 2021 by government order due to the COVID-19 pandemic; 
(b) experienced a specified decline in gross receipts during the eligibility periods 
during 2020 or the first three calendar quarters of 2021; or (c) qualified as a 
recovery startup business for the third or fourth quarters of 2021.  
7. 
The Families First Coronavirus Response Act provided for eligible 
employers to receive refundable tax credits for wages paid to employees while on 
sick leave to recover from any injury, disability, illness, or condition resulting from 
COVID-19 or wages paid to employees while on family leave to care for a family 
member who was injured, disabled, ill, or otherwise suffering from a condition due 
to COVID-19.  Together these credits are called the Sick and Family Leave Wage 
Credit (“SFLC”).  
8. 
Employers were entitled to receive a dollar-for-dollar credit for 
qualified wages paid to an employee, plus allocable health plan expenses and the 
employer’s share of Medicare taxes, while that employee was on sick leave resulting 
from COVID-19.  This credit was limited to up to ten days of sick leave per 
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employee for the period ending March 31, 2021.  That resulted in a maximum credit 
$5,110 per employee for that period.  The American Rescue Plan Act (“ARPA”) 
provided an identical credit for the period April 1, 2021 through September 30, 2021 
with an identical maximum of $5,110 in credits per employee.  
9. 
Employers were entitled to receive a credit of up to two-thirds of the 
qualified wages paid to an employee while that employee was on family leave to 
care for a family member suffering from a condition resulting from COVID-19, plus 
allocable health plan expenses and the employer’s share of Medicare taxes.  For the 
period ending March 31, 2021, this credit was limited to up to $200 per day for up to 
ten weeks, resulting in a maximum eligible credit of $10,000 per employee.  The 
ARPA provided an identical credit for the period April 1, 2021 through September 
30, 2021 and extended the length of family leave to twelve weeks, thereby raising 
the maximum eligible credit for that period to $12,000 per employee.  
10. 
Together, the ERC and SFLC are referred to herein as COVID-Related 
Tax Credits.  
11. 
COVID-Related Tax Credits were claimed by an employer by filing a 
Form 941 or an Adjusted Employer’s Quarterly Federal Tax Return or Claim for 
Refund, Form 941X, with the IRS for the relevant quarter.  
12. 
The same wages could not be used as both qualified sick leave wages 
and qualified family leave wages.  
13. 
Employers were not eligible to receive both the ERC and SFLC with 
respect to the same wages.  
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Leon Haynes 
14. 
HAYNES resided in Teaneck and Bogota, New Jersey, and he provided 
clients tax preparation services.  
15. 
HAYNES purported to own and operate the following businesses, each 
purportedly located in New Jersey: 
A. 
Leons Tax Services, a tax preparation company; 
B. 
GHP Payroll and Business Services (“GHP”), a supposed payroll 
services business; 
C. 
CNL Rentals, a car rental business; and 
D. 
A restaurant called Lyla Mediterranean 2 Go.  
COVID-Related Tax Credit Scheme 
16. 
From at least as early as in or around November 2020 through in or 
around May 2023, HAYNES facilitated a scheme to fraudulently obtain COVID-
Related Tax Credits from the U.S. Treasury by preparing and filing with the IRS at 
least 1,600 false and fraudulent Forms 941, including false and fraudulent Forms 
941 filed on behalf of his own businesses, claiming tax refunds based on COVID-
Related Tax Credits totaling approximately $151,000,000.  As a result of the 
scheme, the U.S. Treasury disbursed at least $40,000,000 in tax refunds to 
HAYNES and his clients.  
17. 
HAYNES and his clients were not entitled to the amount of COVID-
Related Tax Credits or resulting refunds claimed on the Forms 941 HAYNES 
prepared and filed.   
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18. 
Many of the Forms 941 HAYNES prepared were false and fraudulent 
because they listed employees and wages that, in fact, did not actually exist. 
HAYNES used these fake employees and wages to claim COVID-Related Tax 
Credits and, in so doing, fraudulently caused the U.S. Treasury to issue tax refunds.   
19. 
Furthermore, nearly all the Forms 941 HAYNES prepared were false 
in that they sought more funds than the programs allowed.  For example, nearly 
every Form 941 HAYNES prepared either: 
A. 
claimed an ERC above the maximum allowed based on the 
number of employees and wages reported;  
B. 
claimed an SFLC in excess of the amount of wages reported; 
C. 
listed the same wages as both qualified sick leave wages and 
qualified family leave wages; and/or 
D. 
claimed an SFLC and ERC for the same wages.  
20. 
HAYNES generally told his clients that the U.S. Government was 
providing COVID-19 relief to people with small businesses and falsely represented 
that his clients were entitled to receive the tax refunds they ultimately received 
from the U.S. Treasury as a result of HAYNES’ preparation of false and fraudulent 
tax returns.   
21. 
HAYNES profited from the scheme by either (a) receiving tax refunds 
based on false Forms 941 he submitted for one of his own purported companies, or 
(b) by collecting a fee from clients, typically in cash, that HAYNES generally 
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calculated as a percentage of any client’s fraudulently obtained tax refund from 
HAYNES’ false Form 941 scheme.  
22. 
In or around 2023, after learning he was under criminal investigation 
for preparing false Forms 941, HAYNES prepared and filed false Forms 941, 
including at least three false returns that he prepared and filed after speaking 
directly to law enforcement about the investigation in February 2023.   
Individual-1 
23. 
Individual-1, a taxpayer who resided in New Jersey, used HAYNES for 
tax preparation services.  Individual-1 owned and operated a cosmetics business 
(“Business A”).  
24. 
In or around 2021, HAYNES approached Individual-1 about 
Individual-1’s eligibility to receive money from the U.S. Government for COVID-
relief despite HAYNES knowing that Business A did not have employees or operate 
a payroll.  
25. 
Based on HAYNES’ representations, Individual-1 told HAYNES to 
complete the necessary forms to receive the COVID-relief funds to which HAYNES 
said Individual-1 was entitled.  
26. 
On or about the following dates, for the following quarters, HAYNES 
prepared and filed and caused to be filed with the IRS false Forms 941 on behalf of 
Individual-1 for Business A claiming COVID-Related Tax Credits.  These Forms 
941 were false in that they reported Business A had employees, paid wages to 
employees, and paid sick and family leave wages, among other false items:  
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Approx. Date 
Form 941 was 
Received by IRS 
Tax Period 
Refund 
Requested 
2/23/2021 
2020 Q2 
$52,412.50 
2/23/2021 
2020 Q3 
$49,744.42 
2/23/2021 
2020 Q4 
$50,385.00 
6/11/2021 
2021 Q1 
$52,209.42 
7/31/2021 
2021 Q2 
$106,789.03 
10/31/2021 
2021 Q3 
$196,837.36 
6/12/2022 
2021 Q4  
$103,516.41 
6/12/2022 
2022 Q1 
$97,071.67 
 
27. 
HAYNES affixed and caused to be affixed Individual-1’s signature on 
Forms 8453-EMP associated with the false Forms 941. 
28. 
Despite preparing the Forms 941 and being paid to do so, HAYNES did 
not list himself as the tax preparer on the Forms 941 he prepared and filed for 
Business A.  
29. 
The U.S. Treasury paid Individual-1 tax refunds totaling 
approximately $693,493 as a result of the fraudulent COVID-Related Tax Credits 
claimed on the false Forms 941 that HAYNES prepared and filed.  
30. 
At HAYNES’ request, Individual-1 paid HAYNES approximately 
$10,000 in cash for preparing the false Forms 941.  
Individual-2  
31. 
Individual-2, a taxpayer who resided in New Jersey, used HAYNES to 
prepare his Individual Income Tax Returns since approximately 2015.  Individual-2 
owned and operated a construction business (“Business B”).  
32. 
In or around late 2020 or early 2021, HAYNES told Individual-2, in 
substance, that Individual-2 was eligible to receive money from the U.S. 
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Government for COVID-19 relief because Individual-2 had a business.  HAYNES 
knew that Business B did not have employees or operate a payroll, but he did not 
tell Individual-2 that only businesses that paid wages to employees were eligible for 
the COVID-19 relief.  Based on HAYNES’ representations and omissions, 
Individual-2 authorized HAYNES to apply for COVID-19 relief for Business B.  
33. 
On or about the following dates, for the following quarters, HAYNES 
prepared and filed and caused to be filed with the IRS false Forms 941 on behalf of 
Individual-2 for Business B claiming COVID-Related Tax Credits.  These returns 
were false in that they reported Business B had employees, paid wages to 
employees, and paid sick and family leave wages, among other false items: 
Approx. Date 
Form 941 was 
Received by IRS 
Tax Period 
Refund 
Requested 
1/8/2021 
2020 Q2 
$25,557 
1/8/2021 
2020 Q3 
$2,498 
1/8/2021 
2020 Q4 
$24,941 
4/3/2021 
2021 Q1 
$78,157 
7/2/2021 
2021 Q2 
$96,256 
11/19/2021 
2021 Q3 
$174,839 
2/6/2022 
2021 Q4  
$136,884 
 
34. 
Unbeknownst to Individual-2, HAYNES affixed and caused to be 
affixed Individual-2’s signature on Forms 8453-EMP associated with the false 
Forms 941. 
35. 
The U.S. Treasury paid Individual-2 approximately $527,437 as a 
result of the fraudulent COVID-Related Tax Credits claimed on the false Forms 941 
HAYNES prepared and filed.  
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36. 
At HAYNES’ request, Individual-2 paid HAYNES approximately 
$35,000 in cash from the fraudulently obtained tax refund checks.  
37. 
Despite preparing the Forms 941, and subsequently being paid to do 
so, HAYNES did not list himself as the tax preparer on the false Forms 941 he 
prepared and filed for Individual-2.  
38. 
At some point after Individual-2 received some of the fraudulently 
obtained tax refund checks, HAYNES asked Individual-2 to provide him with the 
names and social security numbers of Business B’s employees. HAYNES told 
Individual-2 that this information would facilitate additional requests for COVID-
19 relief funds.  In response, Individual-2 told HAYNES that his business did not 
have any employees.  
Individual-3 
39. 
Individual-3, a taxpayer who resided in New Jersey, began using 
HAYNES’ tax preparation services for his Individual Income Tax Returns in or 
around 2018.  Individual-3 owned and operated an HVAC and heating business 
(“Business C”).  
40. 
At HAYNES’ request, in the course of preparing Individual-3’s 
Individual Income Tax Returns for 2018 and 2019, Individual-3 provided HAYNES 
with information about Individual 3’s income, Business C’s gross receipts and 
expenses, and his personal identifying information, including Individual-3’s social 
security number, credit card number, home address, email address, telephone 
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number, EIN for Business C, and other information.  Individual-3 told HAYNES 
that Business C did not have any employees.  
41. 
Unbeknownst to Individual-3 and without Individual-3’s authorization, 
on or about the following dates, for the following quarters, HAYNES used, without 
Individual-3’s consent or authorization, Individual-3’s personal identifying 
information to prepare and file and cause to be filed false Forms 941 with the IRS 
on behalf of Individual-3 for Business C claiming COVID-Related Tax Credits.  
These returns were false in that they reported Business C had employees, paid 
wages to employees, and paid sick and family leave wages, among other false items:  
Approx. Date 
Form 941 was 
Received by IRS 
Tax Period 
Refund 
Requested 
3/26/2021 
2020 Q2 
$41,443 
3/26/2021 
2020 Q3 
$40,283 
3/26/2021 
2020 Q4 
$40,495 
4/29/2021 
2021 Q1 
$51,761 
 
42. 
Unbeknownst to Individual-3 and without Individual-3’s authorization, 
HAYNES affixed and caused to be affixed Individual-3’s signature on Forms 8453-
EMP associated with the false Forms 941. 
43. 
Despite preparing the Forms 941, HAYNES did not list himself as the 
tax preparer on the false Forms 941 he prepared without Individual-3’s knowledge.  
44. 
As a result of the false Forms 941 HAYNES prepared and filed, in or 
around late April 2021, Individual-3 received three tax refund checks from the U.S. 
Treasury totaling approximately $119,137.  
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45. 
When Individual-3 subsequently called HAYNES to express concern 
about the legality of receiving these checks, HAYNES responded by asking 
Indvidual-5 to pay him approximately $10,000 for each check Individual-3 received.  
And after Individual-3 indicated that he was going to contact the IRS and return 
the money, HAYNES became agitated and told Individual-3, in substance, not to 
contact the IRS and not to return the money.  
46. 
On or about May 5, 2021, HAYNES sent Individual-3’s spouse a text 
message, which stated, in part: 
“My friends, I have nothing at all to fear with what I’m doing, but don’t 
send those checks back to them; and if you already deposited them, just 
leave it and let god do his work, but if you didn’t deposit it yet, just take 
a lighter to it leave it at that and then I will amend everything and 
reverse it like it never happened, but I’m at a loss for words, but no 
matter what, I still love you guys forever and no hard feelings, just don’t 
stir up unnecessary shit by sending checks back is all [. . . .]” 
 
47. 
HAYNES never amended the Forms 941 he prepared and filed on 
behalf of Individual-3 for Business C.  
Individual-4 
48. 
In or around 2020, Individual-4, a taxpayer who resided in New 
Jersey, wanted to start a trucking business (“Business D”).  Business D never 
actually operated.      
49. 
Individual-4 spoke with HAYNES about possible funds or grants 
Individual-4 could access to launch Business D.  HAYNES requested, and 
Individual-4 provided, Individual-4’s background information, including Business 
D’s name and other personal identifying information.  HAYNES and Individual-4 
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did not discuss Forms 941 or the ERC.  After that conversation, Individual-4 and 
HAYNES did not speak again.  
50. 
Unbeknownst to Individual-4 and without Individual-4’s authorization, 
on or about the following dates, for the following quarters, HAYNES prepared and 
filed and caused to be filed with the IRS false Forms 941 on behalf of Individual-4 
for Business D claiming COVID-Related Tax Credits.  The returns were false in 
that they reported Business D had employees, paid wages to employees, and paid 
sick and family leave wages, among other false items:  
Approx. Date 
Form 941 was 
Received by IRS 
Tax Period 
Refund 
Requested 
4/23/2021 
2020 Q2 
$31,866 
4/23/2021 
2020 Q3 
$37,833 
4/23/2021 
2020 Q4 
$25,948 
 
51. 
Unbeknownst to Individual-4, HAYNES affixed and caused to be 
affixed Indvidual-4’s signature on Forms 8453-EMP associated with the false Forms 
941. 
52. 
Despite preparing the Forms 941, HAYNES did not list himself as the 
tax preparer on the false Forms 941 he prepared without Individual-4’s knowledge.  
53. 
Individual-4 did not receive any tax refund checks as a result of the 
false Forms 941 HAYNES prepared and filed. 
HAYNES’ Tax Evasion 
54. 
From 2021 through 2022, HAYNES received more than $1.8 million 
from clients for whom he submitted false Forms 941.  
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55. 
On or about June 8, 2022, HAYNES filed a false U.S. Individual 
Income Tax Return for himself for 2021 that failed to report all of the income he 
received from clients for preparing false Forms 941.  
56. 
On or about July 7, 2023, HAYNES filed a false U.S. Individual Income 
Tax Return for himself for 2022 that failed to report all of the income he received 
from clients for preparing false Forms 941.  
False 941s for HAYNES’ Businesses 
57. 
From at least 2020 through 2022, HAYNES purported to own and 
operate Leons Tax Services, GHP Payroll, CNL Rentals, and Lyla Mediterranean 2 
Go.  
58. 
On or about February 27, 2023, HAYNES voluntarily spoke to law 
enforcement about its ongoing investigation into his tax preparation activities. 
During that meeting, HAYNES stated, in substance, that his businesses only hired 
contractors, not employees, and did not pay them for time they did not work.   
59. 
On or about the following dates, for the following quarters, HAYNES 
prepared and filed and caused to be filed with the IRS false Forms 941 on behalf of 
his businesses falsely claiming COVID-Related Tax Credits.  The returns were false 
in that they reported that the businesses paid wages to employees and paid 
employees sick and family leave wages when, in fact, they had not, among other 
false items:  
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Business 
Tax Period 
Approx. Date Form 
941 was Received by 
IRS 
Refund 
Requested 
Leons Tax Service 
Q2 2020 
11/8/2020 
 $77,753 
Leons Tax Service 
Q3 2020 
11/8/2020 
 $62,651  
Leons Tax Service 
Q4 2020 
12/24/2020 
$104,852  
CNL  
Q2 2020 
2/15/2021 
 $73,186  
CNL  
Q3 2020 
2/15/2021 
 $57,538 
CNL  
Q4 2020 
2/15/2021 
 $68,866 
Leons Tax Service 
Q1 2021 
4/1/2021 
$203,866  
CNL  
Q1 2021 
5/29/2021 
$117,271  
Leons Tax Service 
Q2 2021 
7/11/2021 
$258,280  
CNL Rentals 
Q2 2021 
7/12/2021 
$184,113 
GHP  
Q2 2020 
7/12/2021 
 $58,212 
GHP  
Q3 2020 
7/12/2021 
 $42,320 
GHP  
Q4 2020 
7/12/2021 
 $42,748  
GHP  
Q1 2021 
7/12/2021 
 $59,018  
GHP  
Q2 2021 
7/13/2021 
 $62,858  
Lyla Mediterranean 
Q2 2021 
7/17/2021 
$107,938  
Lyla Mediterranean 
Q1 2021 
7/23/2021 
 $74,414 
Lyla Mediterranean 
Q4 2020 
8/16/2021 
 $44,787 
CNL  
Q3 2021 
9/27/2021 
 200,729  
Leons Tax Service 
Q3 2021 
9/30/2021 
$243,071 
Lyla Mediterranean 
Q3 2021 
9/30/2021 
$203,947  
GHP  
Q3 2021 
10/23/2021 
$210,535  
CNL  
Q4 2021 
1/3/2022 
$215,954  
GHP  
Q4 2021 
1/3/2022 
$195,140  
Leons Tax Service 
Q4 2021 
1/3/2022 
$281,378  
Lyla Mediterranean 
Q4 2021 
1/3/2022 
$269,669  
GHP  
Q1 2022 
6/7/2022 
$114,614 
CNL  
Q1 2022 
6/8/2022 
$181,559  
Leons Tax Service 
Q1 2022 
6/8/2022 
$175,246 
Lyla Mediterranean 
Q1 2022 
6/8/2022 
$211,349 
GHP Payroll 
Q2 2022 
7/6/2022 
$175,204  
Leons Tax Service 
Q2 2022 
7/6/2022 
$274,309 
Lyla Mediterranean 
Q2 2022 
7/7/2022 
$175,388  
 
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60. 
By filing false tax returns fraudulently claiming COVID-related Tax 
Credits, HAYNES caused the U.S. Treasury to mail him the following tax refund 
checks, which totaled approximately $1,428,592: 
Tax 
Period 
Business  
Approx.  
Date U.S. 
Treasury 
Check Issued 
Location 
Check 
Mailed From 
Location 
Check 
Mailed To 
Amount of 
Check 
Issued  
2020 Q2 
Leons Tax 
Services  
12/22/2020 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$78,838.96 
2020 Q3 
Leons Tax 
Services  
12/17/2020 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$63,736.96  
2020 Q4 
Leons Tax 
Services  
2/23/2021 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$35,362.88 
2021 Q1 
Leons Tax 
Services  
5/252021 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$199,209.50 
2021 Q2 
Leons Tax 
Services  
8/24/2021 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$254,117.36 
2022 Q3  
Leons Tax 
Services  
11/22/2022 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$160,230.13 
2020 Q2 
CNL 
Rentals 
3/23/2021 
Kansas City, 
Missouri 
Teaneck, 
New Jersey 
$71,417.00 
2020 Q3 
CNL 
Rentals 
3/30/2021 
Kansas City, 
Missouri 
Teaneck, 
New Jersey 
$56,056.71 
2020 Q4 
CNL 
Rentals 
8/10/2021 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$68,014.16 
2021 Q2 
CNL 
Rentals 
8/24/2021 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$181,213.03 
2021 Q4 
CNL 
Rentals 
2/22/2022 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$195,967.52 
 
61. 
On or about the following dates, the SSA sent letters to HAYNES 
regarding the businesses listed below.  In each letter, the SSA informed HAYNES 
that the wage information he reported on the Forms 941 filed with the IRS did not 
match the wages that were reported to the SSA on forms W-2 and requested that he 
fill out a questionnaire: 
 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 17 of 28 PageID: 251

 
 
18 
 
Date 
Tax Period 
Entity 
July 1, 2022 
2020 
Leons Tax Services  
July 1, 2022 
2020 
CNL Rentals 
Feb. 25, 2022 
2020 
CNL Rentals 
Dec. 23, 2022 
2020 
CNL Rentals 
Jan. 20, 2023 
2020 
Leons Tax Services 
Feb. 10, 2023 
2020 
CNL Rentals 
Feb. 24, 2023 
2021 
CNL Rentals  
 
62. 
After HAYNES received the two July 1, 2022 letters referenced above, 
he returned two questionnaires to the SSA.  On each questionnaire HAYNES wrote: 
I am the owners [sic] and operator of said business listed 
on this form. I certify that the compensation that was 
reported to Social Security is attributed to the Employee 
Retention Credit and Family and Sick leave. Furthermore, 
the compensation that was reported is inaccurate.  
 
 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 18 of 28 PageID: 252

 
 
19 
 
 
COUNTS 1-18 
(Aiding and Assisting in the Preparation of False Returns) 
 
63. 
The allegations in paragraphs 1 through 62 of this Indictment are 
realleged here.  
64. 
On or about the dates set forth below, in the District of New Jersey, 
and elsewhere, the defendant, 
LEON HAYNES, 
 
did willfully aid and assist in, procure, counsel, and advise in the preparation and 
presentation to the Internal Revenue Service of Employer’s Quarterly Federal Tax 
Returns, Forms 941, for the periods stated below, which were false and fraudulent 
as to one or more material matters, and which HAYNES did not believe to be true 
and correct as to every material matter in that each return falsely asserted that the 
business reported on the return was entitled to receive more COVID-Related Tax 
Credits than it was actually entitled to receive, among other false items, each 
constituting a separate count of this Indictment.  
Count 
Individual 
Associated 
with Business 
Tax Period 
Approx. 
Date 
Received 
by IRS 
Form 941 
False Items 
1 
Individual-1 
2020 Q2 
2/23/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
2 
Individual-1 
2020 Q3 
2/23/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 19 of 28 PageID: 253

 
 
20 
 
3 
Individual-1 
2020 Q4 
2/23/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
4 
Individual-1 
2021 Q1 
6/12/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
5 
Individual-1 
2021 Q2 
7/20/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13g, Total deposits and 
refundable credits. 
iv. Line 15, Overpayment 
6 
Individual-1 
2021 Q3 
10/06/2021 i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13g, Total deposits and 
refundable credits. 
iv. Line 15, Overpayment 
7 
Individual-1 
2021 Q4 
6/12/2022 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13g, Total deposits and 
refundable credits. 
iv. Line 15, Overpayment 
8 
Individual-1 
2022 Q1 
6/12/2022 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13g, Total deposits and 
refundable credits. 
iv. Line 15, Overpayment 
9 
Individual-2 
2020 Q2 
1/8/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
10 
Individual-2 
2020 Q3 
1/8/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 20 of 28 PageID: 254

 
 
21 
 
11 
Individual-2 
2020 Q4 
1/8/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
12 
Individual-2 
2021 Q1 
4/3/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
13 
Individual-2 
2021 Q2 
7/2/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13g, Total deposits and 
refundable credits. 
iv. Line 15, Overpayment 
14 
Individual-2 
2021 Q3 
11/9/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13g, Total deposits and 
refundable credits. 
iv. Line 15, Overpayment 
15 
Individual-2 
2021 Q4 
2/6/2022 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13g, Total deposits and 
refundable credits. 
iv. Line 15, Overpayment 
16 
Individual-4 
2020 Q2 
4/23/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
17 
Individual-4 
2020 Q3 
4/23/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
18 
Individual-4 
2020 Q4 
4/23/2021 
i. Line 1, number of employees;  
ii. Line 2, wages, tips, and other 
compensation; 
iii. Line 13e, Total deposits, 
deferrals, and refundable credits. 
iv. Line 15, Overpayment 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 21 of 28 PageID: 255

 
 
22 
 
 
 
In violation of Title 26, United States Code, Section 7206(2).  
 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 22 of 28 PageID: 256

 
 
23 
 
COUNTS 19-22 
(Mail Fraud) 
 
 
65. 
The allegations in paragraphs 1 through 62 of this Indictment are 
realleged here.  
66. 
From as early as in or around April 2021 through in or around June 
2021, in the District of New Jersey, and elsewhere, the defendant, 
LEON HAYNES, 
 
knowingly and intentionally devised and intended to devise a scheme and artifice to 
defraud the Internal Revenue Service and to obtain money and property by means 
of materially false and fraudulent pretenses, representations, and promises, 
including by filing false Forms 941 claiming COVID-Related Tax Credits for 
Business C, and, for the purpose of executing and attempting to execute such 
scheme and artifice, did knowingly transmit and cause to be transmitted by means 
of the mails in interstate and foreign commerce, the following mailings, each 
constituting a separate count of this Indictment:  
Count 
Tax Period 
Approx.  
Date U.S. 
Treasury 
Check Issued 
Location 
Check Mailed 
From 
Location 
Check Mailed 
To 
Amount of 
Check 
Issued  
19 
2020 Q2 
4/27/2021 
Kansas City, 
Missouri 
Newark, New 
Jersey 
$40,438.03 
20 
2020 Q3 
4/27/2021 
Kansas City, 
Missouri 
Newark, New 
Jersey 
$39,246.30  
21 
2020 Q4 
4/27/2021 
Kansas City, 
Missouri 
Newark, New 
Jersey 
$39,452.53 
22 
2021 Q1 
6/1/2021 
Kansas City, 
Missouri 
Newark, New 
Jersey 
$50,608.90 
 
 
In violation of Title 18, United States Code, Section 1341.  
 
 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 23 of 28 PageID: 257

 
 
24 
 
COUNT 23  
(Aggravated Identity Theft) 
 
 
67. 
The allegations in paragraphs 1 through 62 of this Indictment are 
realleged here.  
68. 
On or about March 26, 2021, in the District of New Jersey, and 
elsewhere, the defendant, 
LEON HAYNES, 
 
did knowingly transfer, possess, and use, without lawful authority, a means of 
identification of another person, namely Individual-3, during and in relation to a 
felony violation enumerated in Title 18, United States Code, Section 1028A(c)(5), 
that is, mail fraud, in violation of Title 18, United States Code, Section 1341, as 
charged in Count 19 of this Indictment, knowing that the means of identification 
belonged to another actual person.  
In violation of Title 18, United States Code, Section 1028A and Section 2.  
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 24 of 28 PageID: 258

 
 
25 
 
COUNT 24 
(Mail Fraud) 
 
69. 
The allegations in paragraphs 1 through 62 of this Indictment are 
realleged and incorporated here.  
70. 
From in or around November 2020, through in or around January 
2023, in the District of New Jersey, and elsewhere, the defendant, 
LEON HAYNES, 
 
knowingly and intentionally devised and intended to devise a scheme and artifice to 
defraud the Internal Revenue Service and to obtain money and property by means 
of materially false and fraudulent pretenses, representations, and promises, 
including by filing false Employer’s Quarterly Federal Tax Returns, Forms 941, 
claiming COVID-Related Tax Credits for HAYNES’ purported companies and, for 
the purpose of executing and attempting to execute such scheme and artifice, did 
knowingly transmit and cause to be transmitted by means of the mails in interstate 
and foreign commerce, the following mailing:  
Tax 
Period 
Business  
Approx.  
Date U.S. 
Treasury 
Check Issued 
Location 
Check 
Mailed From 
Location 
Check 
Mailed To 
Amount of 
Check 
Issued  
2021 Q2 
Leons Tax 
Services  
8/24/2021 
Kansas City, 
Missouri 
Bogota, 
New Jersey 
$254,117.36 
 
 
In violation of Title 18, United States Code, Section 1341.  
 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 25 of 28 PageID: 259

 
 
26 
 
COUNTS 25-26 
(Tax Evasion) 
 
71. 
The allegations in paragraphs 1 through 62 of this Indictment are 
realleged here.  
72. 
From in or around 2021 through in or around 2023, in the District of 
New Jersey, and elsewhere, the defendant, 
LEON HAYNES, 
 
did willfully attempt to evade and defeat income tax due and owing by him to the 
United States of America, for the calendar years listed below, by committing the 
following affirmative acts of evasion, among others: 
a. 
Requesting that his clients pay him in cash, and accepting cash, 
for preparing false Forms 941 fraudulently claiming COVID-related 
tax credits; and 
b. 
Preparing and causing to be prepared, and signing and causing 
to be signed, false and fraudulent Individual Income Tax Returns, 
Forms 1040, which were submitted to the IRS. 
Count 
Tax Year 
Taxpayer 
25 
2021 
LEON HAYNES 
26 
2022 
LEON HAYNES 
 
 
In violation of Title 26, United States Code, Section 7201.  
 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 26 of 28 PageID: 260

 
 
27 
 
FORFEITURE ALLEGATIONS AS TO COUNTS 19-22 and 24 
 
1. 
Upon conviction of the offenses charged in Counts 19 through 22 and 
24 of this Indictment, the defendant, 
LEON HAYNES, 
 
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 
981(a)(1)(C), and Title 28, United States Code, Section 2461(c), all property, real 
and personal, that constitutes or is derived from proceeds traceable to the 
commission of the offenses charged in Counts 19 through 22 and 24 of this 
Indictment, and all property traceable thereto.  
2. 
If any of the above-described forfeitable property, as a result of any act 
or omission of the defendant: 
A. cannot be located upon the exercise of due diligence; 
 
B. has been transferred or sold to, or deposited with, a third 
person; 
 
C. has been placed beyond the jurisdiction of the Court; 
 
D. has been substantially diminished in value; or 
 
E. has been commingled with other property which cannot be 
subdivided without difficulty, 
 
 
 
 
 
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28 
it is the intent of the United States, pursuant to Title 21, United States Code, 
Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c), to 
seek forfeiture or any other property of the defendant up to the value of the above-
described forfeitable property.  
A TRUE BILL. 
FOREPERSON 
________________________ 
PHILIP R. SELLINGER  
United States Attorney 
Case 2:24-cr-00232-WJM     Document 54     Filed 07/22/25     Page 28 of 28 PageID: 262

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