Indictment — United States v. Renata Walton and Nicole Jones (Dkt. 2, W.D. Tenn.)

Summary

An Indictment filed November 21, 2024 as Document 2 in United States of America v. Renata Walton and Nicole Jones a/k/a Nicole Dickerson, Case No. 2:24-cr-20213-MSN, in the U.S. District Court for the Western District of Tennessee, Western Division. The caption lists 18 U.S.C. §§ 1343, 1349, 1512 and 1957 and 26 U.S.C. §§ 7203 and 7206. The Indictment alleges that Walton and Jones are tax preparers at R&B Tax Express in Moscow, Tennessee who, through different COVID-relief fraud schemes, defrauded and attempted to defraud the United States out of over $65,000,000 in the years 2020 through 2024. It alleges false statements on Forms 944, Forms 1040 and schedules claiming Employee Retention Credits, Sick and Family Leave Credits and education credits. The forfeiture sections reference specific counts.

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Full text

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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION
UNITED STATES OF AMERICA,
)
)
Cr. No.:  ______________
Plaintiff,
)
)
vs.
)
18 U.S.C. § 1343
)
18 U.S.C. § 1349
)
18 U.S.C. § 1512
RENATA WALTON,
)
18 U.S.C. § 1957
AND
)
26 U.S.C. § 7203
NICOLE JONES,
)
26 U.S.C. § 7206
A/K/A NICOLE DICKERSON,
)
)
Defendants.
)

I N D I C T M E N T
THE GRAND JURY CHARGES:
Overview
1.
On March 23, 2020, the President declared the COVID-19 pandemic a
national emergency, as defined in Title 42, United States Code, Section 5122(a).
Thereafter, the 116th United States Congress passed a number of laws aimed at
alleviating the economic strain brought on by the pandemic, i.e. COVID-relief.
2.
Defendants Renata Walton and Nicole Jones are tax preparers at R&B
Tax Express in Moscow, Tennessee, who through different COVID-relief fraud schemes
defrauded and attempted to defraud the United States out of over $65,000,000 in the
years 2020 through 2024.
BATEMAN
24-20213 MSN-cgc
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Tax Returns and COVID-19 Tax Credits

3.
The Internal Revenue Service (“IRS”) governs and administers federal
income taxation.
4.
An individual tax return, Form 1040, U.S. Individual Income Tax Return
(“Form 1040”), is an official report that calculates a taxpayer’s total tax liability, often
using financial information such as total income, and determines if there is an over or
under payment of taxes. In the event of an overpayment, a taxpayer is entitled to a
refund.
5.
A Schedule C Profit or Loss from Business (“Schedule C”) is attached as
an optional supplement to the Form 1040. The purpose of a Schedule C is to report
income or loss from a business operated or a profession practiced as a sole proprietor.
An activity qualifies as a business if the primary purpose for engaging in the activity is
for income or profit and the taxpayer is involved in the activity with continuity and
regularity. A return with a Schedule C loss reported will lower the taxable income on the
Form 1040 tax return and reduce the tax amount.
6.
A Schedule H, Household Employment Taxes (“Schedule H”) reports to
the IRS household employment taxes owed by an individual that paid wages to a
household employee(s) and whether the wages were subject to social security,
Medicare or Federal Unemployment Tax Act (“FUTA”) taxes, or if federal income taxes
were withheld from the employee(s).  A Schedule H is filed with an individual’s Form
1040, or by itself.
7.
The IRS gives several examples of household employees: butlers,
caretakers, cooks, maids, nannies, private nurses, drivers, and cleaning people.  If an
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individual has household employee(s) that are paid wages of $2,400 or more in 2022
and/or $2,600 or more in 2023, the employer should withhold social security and
Medicare taxes from the employee(s), file Forms W-2 with the IRS, and file Forms W-3
to the Social Security Administration.
8.
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”).
9.
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 employee for the period
ending March 31, 2021.  That resulted in a maximum credit of $5,110 per employee for
that period.  The American Rescue Plan Act (“ARPA”) provided a similar credit for the
period April 1, 2021 through September 30, 2021 also with a maximum of $5,110 in
credits per employee.
10.
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
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weeks, resulting in a maximum eligible credit of $10,000 per employee.  The ARPA
provided a similar 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.
11.
Employers would claim the SFLC credits for their household employees
on the Schedule H addendum to their Form 1040.
12.
Form 7202, Credits for Sick and Family Leave for Certain Self-employed
Individuals is used to calculate refundable qualified sick and family leave equivalent
credits if a taxpayer herself was unable to perform services as an eligible self-employed
individual due to certain COVID-19 related circumstances between April 1, 2020 and
September 30, 2021.
13.
To qualify for the credit, the taxpayer must have met one or more of the
following: regularly carried on a trade or business, or was a partner in such a business;
been subject to federal, state or local quarantine or isolation due to COVID-19; been
advised to self-quarantine by a health professional due to COVID-19; cared for an
individual or family member who was subject to the above mentioned COVID-19
quarantine concerns, among other restrictions. The credit is included on the self-
employed individual’s personal Form 1040 and reduces their tax liability. Any payments
or credits that exceed the taxpayer’s tax liability are issued in the form of a federal
income tax refund to the taxpayer.
14.
The Coronavirus Aid, Relief, Taxpayer Certainty and Disaster Tax Relief
Act of 2020 (“CARES Act”) provided in part for an Employee Retention tax Credit
(“ERC”). ERC was designed to encourage employers to continue to pay employees
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during COVID-19. The ERC is a tax credit available to eligible employers with business
operations that were partially or fully suspended due to governmental orders during
March 12, 2020, but before January 1, 2022, saw significant decline in gross receipts as
compared to pre-COVID-19 tax periods, or were adversely impacted by supply chain
disruptions.
15.
ERC is equivalent up to 50% of qualified wages paid for the 2020 tax year
and up to 70% for the 2021 tax year and is credited against applicable employment tax
liability (social security tax and Medicare tax). If the credit exceeds the employment tax
due, a refund is issued. ERC would have to be claimed on a business tax return filing,
such as a Form 944, Employer’s Annual Federal Tax Return (“Form 944”).
16.
A Form 944 is reserved for small employers whose annual tax liability is
$1,000 or less. To be eligible to file a Form 944, the employer must be notified by the
IRS. Employers file this form to report income taxes, social security, and Medicare taxes
withheld from employees’ wages, among other items to the IRS. This form is also used
to calculate and report the employer’s portion of social security and Medicare tax they
owe to the IRS. If the total deposits and credits exceed the employer’s employment tax
liability, the excess is issued to the employer in the form of a federal income tax refund.
This form is filed in lieu of a Form 941, which is the tax return, filed quarterly, that
businesses whose annual employment tax liability is over $1,000 file.
17.
An E-File Declaration for Employment Tax returns, Form 8453-EMP
(“Form 8453-EMP”), is a form used to authenticate an electronic employment tax return,
authorize an electronic return originator or an intermediate service provider to transmit
an electronic employment tax return via a third party, and authorize an electronic funds
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withdrawal for payment of federal taxes owed.  The Form 8453-EMP is required to be
signed by an authorized individual of the taxpayer business who, in so doing, swears
under penalty of perjury that the tax return was true, correct, and complete and
consents to the electronic return originator or intermediate service provider submitting
the employment tax return to the IRS.
Paycheck Protection Program
18.
The CARES Act also provided COVID-19 relief in the form of authorization
of up to $349 billion in forgivable loans to small businesses for job retention and certain
other expenses, through a program referred to as the Paycheck Protection Program
(“PPP”).  In or around April 2020, Congress authorized over $300 billion in additional
PPP funding.
19.
To obtain a PPP loan, a qualifying business was required to submit a PPP
loan application, signed by an authorized representative of the business.  The PPP loan
application required the business (through its authorized representative) to
acknowledge the program rules and make certain affirmative certifications to be eligible
to obtain the PPP loan.  In the PPP loan application, the small business (through its
authorized representative) was required to state its average monthly payroll expenses
and its number of employees, among other things.  These figures were used to
calculate the amount of money the small business was eligible to receive under the
PPP.  In addition, businesses applying for a PPP loan were required to provide
documentation showing their payroll expenses.
20.
A PPP loan application was processed by a participating financial
institution (“lender”).  If a PPP loan application was approved, the participating lender
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funded the PPP loan using its own monies, which were guaranteed by the Small
Business Association (“SBA”).  Data from the application, including information about
the borrower, the total amount of the loan, and the listed number of employees, was
transmitted by the lender to the SBA in the course of processing the loan.
21.
PPP loan proceeds were required to be used by the business on certain
permissible expenses, including payroll costs, mortgage interest, rent, and utilities.
Under the applicable PPP rules and guidance, the interest and principal on the PPP
loan were eligible for forgiveness if the business was eligible for the PPP loan it
received, spent the loan proceeds on these permissible expense items within a
designated period, and used a certain portion of the loan proceeds for payroll expenses.
Economic Injury Disaster Loan
22.
Another federal government program instituted in response to the COVID-
19 pandemic was an expansion of an existing disaster-related program called the
Economic Injury Disaster Loan (“EIDL”) Program, which provides loan assistance for
small businesses and other eligible entities.  The CARES Act expanded eligibility for the
EIDL Program to assist business entities that suffered “substantial economic injury”
from COVID-19.
23.
EIDL loan funds were to be used for working capital and other normal
operating expenses by eligible businesses. Applicants for EIDL Program loans applied
through the SBA via an online portal.
Defendants
24.
Defendant RENATA WALTON owned and operated R&B Tax Express,
located in Moscow, Tennessee. In her role as owner/operator, WALTON was
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responsible for the operations of R&B Tax Express and personally prepared tax returns
for both individual and business clients.
25.
WALTON has been a tax preparer since 2012 and teaches tax
preparation classes. WALTON, also, sells her own tax preparation software called
Pearson Tax Software.
26.
In addition to R&B Tax Express, WALTON purported to own and operate
the following businesses:
A.
R&B Financial Services;
B.
Pearson Tax Software;
C.
Pearson Fun and Bounce;
D.
Beautique and Style; and
E.
D&K Hair Collection.
27.
Defendant NICOLE JONES worked at R&B Tax Express and prepared tax
returns for both individual and business clients.
28.
JONES purported to own and operate the following businesses:
A.
Hair Save;
B.
Brisk Carriers;
C.
Woods Transportation;
D.
Pearson Family Home Health Care; and
E.
Bling my Jeans.
The Multiple Schemes to Defraud
29.
WALTON and JONES executed and attempted to execute a variety of
schemes to defraud the United States by lying on various types of tax return
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documents, as well as other government forms, for themselves and their clients in order
to obtain monies under false pretenses connected to COVID relief.
30.
The tax return documents on which WALTON and JONES knowingly
provided false information were Forms 944, Forms 1040, and attendant schedules to
Forms 1040. WALTON and JONES would falsely provide on the tax forms that their
clients were entitled to:
A.
Employee Retention Credits;
B.
Sick and Family Leave Credits;
C.
American Opportunity Education Credits; and
D.
Lifetime Learning Tax Credits;
when their clients were not entitled to either the credits at all or not entitled to the extent
provided on the tax return documents prepared by WALTON and JONES.
31.
After entering the false values for the credits that their clients were not
entitled to, WALTON and JONES would send wires in interstate commerce by
submitting the fraudulent tax returns electronically to the IRS along with a Form 8453-
EMP.
Form 944 Employee Retention Credit Fraud Scheme
32.
WALTON and JONES knowingly devised and participated in and
intended to devise and participate in a scheme to defraud and obtain money from the
United States by means of materially false and fraudulent pretenses, representations,
and promises, using interstate wires.
A. WALTON—and JONES by virtue of her association with Walton
and R&B Tax Express—had clients who trusted them because of their pre-existing tax
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preparer-client relationships, because of WALTON’S status as proprietor of Pearson
Tax Software, and because of WALTON’S reputation as a tax preparation teacher;
B. By virtue of WALTON’S and JONES’ relationship with their clients,
they were aware of which of their clients had small businesses;
C. WALTON and JONES would contact their tax clients who had
small businesses and ask them if they were interested in “grant” money that was
available to them;
D. It was part of the scheme that WALTON and JONES would falsely
represent that their clients were eligible for the money, without explaining what the
money was for, where the money was from, or the eligibility requirements of ERC;
E. It was further part of the scheme that WALTON and JONES would
prepare Forms 944 for their clients, many of whom were ineligible to file Forms 944,
with false information, to include,
i. ERC credits that the businesses were not entitled to,
ii. Substantial and fictious wage amounts, and

iii. Claims for a refund;

F. The Forms 944 prepared by WALTON and JONES were blank
except for the business identifying information, employee wage amount, ERC line items,
and refund amount;
G. Further, the Forms 944 included no federal income, medical, or
social security withholdings and no tax liability;
H. The information listed in the Forms 944 was material because the
refund amount was dependent on it;
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I. It was further part of the scheme that WALTON and JONES would
transmit the Forms 944 in interstate commerce by means of wires, that is they would
submit the Forms 944 on a website called Zenwork Tax1099, whose servers were
located in the States of Oregon and Virginia;
J. WALTON and JONES would receive confirmation emails back
from Zenwork after each Form 944 was filed;
K. It was further part of the scheme that the small business clients
would receive U.S. Treasury checks based on the false information provided on the
Forms 944, often in excess of $100,000.
L. After receiving their fraudulent refund, the small business clients
would then pay WALTON and JONES a fee, normally $15,000;
M. In order to avoid detection of the scheme, neither WALTON nor
JONES filed a tax return for tax period 2022 nor did they pay income tax for that period.
N. Beginning in early 2024, WALTON and JONES began sending
their clients pre-drafted letters, in the names of their clients, for them to then send on to
the IRS. These letters included false information that was meant to undermine the IRS’
investigation of WALTON’S and JONES’ ERC scheme.
O. As a part of the Form 944 Employee Retention Credit scheme, in
total, WALTON and JONES filed fraudulent Forms 944 seeking in excess of
$32,000,000 in tax refunds from the United States Treasury.
33.
WALTON’S and JONES’ clients would also receive significant funds from
the federal government for fraudulent 1040 tax returns and PPP loan applications that
WALTON and JONES filed on their behalf. After receiving these funds from the federal
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government, WALTON’S and JONES’ clients would pay WALTON and JONES large
sums of money, often in the form of cashier’s checks.
34.
WALTON was put on notice that the federal government was investigating
her for tax preparation fraud in January 2023, yet she continued to file fraudulent tax
returns. JONES was put on notice that the federal government was investigating her for
tax preparation fraud in May 2024, yet she also continued to file fraudulent tax returns
35.
Beginning in early 2024, WALTON encouraged her tax clients not to
speak with IRS agents.
COUNT 1 – CONSPIRACY TO COMMIT WIRE FRAUD
36.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
37.
From on or about March 1, 2022 to at least on or about August 31, 2023,
in the Western District of Tennessee and elsewhere, the defendants,
RENATA WALTON
AND
NICOLE JONES

did knowingly and willfully conspire and agree with each other and others known and
unknown to the grand jury to commit the offense of Wire Fraud under 18 U.S.C. § 1343,
by knowingly devising and participating in and intending to devise and participate in a
scheme to defraud and obtain money from the United States by means of materially
false and fraudulent pretenses, representations, and promises, using the transmission
of wires, as described in paragraph 32, all in violation of 18 U.S.C. § 1349.

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COUNTS 2-16 – WIRE FRAUD
38.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
39.
Between on or about March 1, 2022, and on or about February 1, 2023, in
the Western District of Tennessee and elsewhere, being aided and abetted by
individuals known and unknown to the grand jury,
RENATA WALTON
knowingly devised and participated in and intended to devise and participate in a
scheme to defraud and to obtain money from the federal government by means of
materially false and fraudulent pretenses, representations, and promises, by the
sending of wires in interstate commerce as provided below, in order to generate
erroneous tax refunds for both herself and her clients who in turn paid fees to WALTON
Count
#
Date
Taxpayer
Tax
Period
Wire Transmission
2
3/24/2022
Pearson Fun &
Bounce
2020
Form 944 claiming a $31,605 refund
3
3/24/2022
D&K Hair Collection
2021
Form 944 claiming a $129,661.00
refund
4
3/24/2022
Pearson Tax
Software
2021
Form 944 claiming a $61,188.40
refund
5
3/24/2022
Beautique & Style
2021
Form 944 claiming a $99,658.30
refund
6
3/24/2022
R&B Financial
Services
2021
Form 944 claiming a $92,616.30
refund
7
5/4/2022
RENATA WALTON
DBA R&B Tax
Express
2020
Form 944 claiming a $189,281.50
refund
8
6/22/2022
R&B Financial
Services
2020
Form 944 claiming a $144,781.50
refund
9
7/14/2022
B.M.C.C.
2021
Form 944 claiming a $137,790.10
refund
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10
7/14/2022
J.O.T.C.
2021
Form 944 claiming a $139,232.80
refund
11
7/14/2022
M.F.Y.
2020
Form 944 claiming a $99,928.10
refund
12
7/14/2022
M.F.Y.
2021
Form 944 claiming a $137,827.20
refund
13
7/26/2022
M.K.
2021
Form 944 claiming a $139,121.67
refund
14
8/17/2022
L.S.PS.
2020
Form 944 claiming a $127,717.80
refund
15
9/21/2022
J.O.T.C.
2020
Form 944 claiming a $129,481
refund
16
9/21/2022
M.K.
2020
Form 944 claiming a $151,284.50
refund

all in violation of 18 U.S.C. § 1343.
COUNTS 17-21
Aiding and Assisting in the Preparation of False Tax Returns

40.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
41.
Between on or about February 1, 2020, and on or about May 1, 2024, in
the Western District of Tennessee and elsewhere, being aided and abetted by
individuals known and unknown to the grand jury, the defendant,
RENATA WALTON
did willfully aid and assist in, procure, counsel, and advise the preparation and
presentation to the Internal Revenue Service, of Form 1040 documents for the
taxpayers and tax periods specified below. The documents were false and fraudulent as
to material matters, in that they represented that the taxpayers were entitled, under the
provisions of the Internal Revenue laws, to claim sick and family leave credits, amongst
other items, that they were not entitled to; whereas defendant WALTON then and there
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knew the taxpayers were not entitled to claim those items that Walton included on their
tax returns, as described below,
Count # Date
Taxpayer Tax
Period
Falsified Items
17
2/10/2022 T.A.
2021
Refund claim of $21,348 and SFLC
credits on Form 7202
18
3/24/2022 C.W.
2021
Refund claim of $5,044 and SFLC
credits on Form 7202
19
5/6/2022
E.S.
2020
Refund claim of $7,295 and SFLC
credits on Form 7202
20
1/30/2024 J.L.
2023
Refund claim of $17,500 and SFLC
credits on Schedule H
21
2/12/2024 C.T.
2023
Refund claim of $16,482 and SFLC
credits on Schedule H

all in violation of 26 U.S.C. 7206(2).
COUNTS 22-26 – WIRE FRAUD
42.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
43.
Between on or about January 1, 2021 and on or about May 1, 2021, in the
Western District of Tennessee and elsewhere, being aided and abetted by individuals
known and unknown to the grand jury, the defendant,
RENATA WALTON
knowingly devised and participated in and intended to devise and participate in a
scheme to defraud and to obtain money from the federal government by means of
materially false and fraudulent pretenses, representations, and promises, by the
sending of wires in interstate commerce as provided below, in order to generate PPP
loans for both herself and her clients who in turn paid fees to WALTON,
Count #
Date
Wire Transmission
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22
1/8/2021
PPP loan application for loan # 2218267200 for R&B Tax
Express claiming $20,800.
23
1/21/2021 PPP loan application for loan # 3267528410 for T. and T. E.
claiming $22,600.
24
2/22/2021 PPP loan application for loan # 4952998501 for B.V.L.H.E. for
$20,833.
25
4/27/2021 PPP loan application for loan # 3673278903 for A.C. claiming
$20,833.00.
26
4/28/2021 PPP loan application for loan # 6099648905
for N.G. and M. claiming $20,833.

all in violation of 18 U.S.C. § 1343.
COUNTS 27-28 – WIRE FRAUD
44.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
45.
Between on or about March 1, 2020, and on or about March 1, 2022, in
the Western District of Tennessee and elsewhere, being aided and abetted by
individuals known and unknown to the grand jury, the defendant,
RENATA WALTON
knowingly devised and participated in and intended to devise and participate in a
scheme to defraud and to obtain money from the federal government by means of
materially false and fraudulent pretenses, representations, and promises, by the
sending of wires in interstate commerce, in order to generate funds from EIDL loans for
herself,
Count #
Date
Wire Transmission
27
4/3/2020
EIDL loan application #3301802703 for Pearson Bounce and
Fun claiming $10,000
28
2/12/2022
EIDL loan application #3318021569 for R&B Financial Service
LLC claiming $122,500

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all in violation of 18 U.S.C. § 1343.
COUNT 29 – OBSTRUCTION OF JUSTICE
46.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
47.
Between on or about January 1, 2024 and on or about July 31, 2024, in
the Western District of Tennessee, the defendant,
RENATA WALTON
did corruptly attempt to influence, obstruct, and impede the foreseeable federal criminal
prosecution of her tax preparation activities, an official proceeding, by drafting, and
causing to be drafted, documents with false information, and sending said documents to
her clients, for them to file with the IRS, such false information including:
a. that the clients entered legitimate business wages on their Forms
944 for purposes of the ERC;
b. that the clients understand the ERC and meet all qualifications for
the ERC; and
c. that the client discussed with R&B Financial all wages paid out for
purposes of ERC in 2020 and 2021;
all in violation of 18 U.S.C. § 1512(c).
COUNTS 30-37 – WIRE FRAUD
48.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
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49.
Between on or about July 1, 2022, and on or about January 1, 2023, in the
Western District of Tennessee and elsewhere, being aided and abetted by individuals
known and unknown to the grand jury,
NICOLE JONES
knowingly devised and participated in and intended to devise and participate in a
scheme to defraud and to obtain money from the federal government by means of
materially false and fraudulent pretenses, representations, and promises, by the
sending of wires in interstate commerce as provided below, in order to generate
erroneous tax refunds for both herself and her clients who in turn paid fees to JONES,
Count
#
Date
Taxpayer Tax
Period
Wire Transmission
30

9/16/2022
F.L.T.
2021
Form 944 claiming a $134,236 refund
31
9/22/2022
C.C.S.
2021
Form 944 claiming a $132,273.40 refund

32

10/16/2022 C.C.S.
2020
Form 944 claiming a $136,685 refund
33

10/16/2022 F.L.T.
2020
Form 944 claiming a $167,302.50 refund
34

10/24/2022 C.P.
2021
Form 944 claiming a $160,687.80 refund
35

10/30/2022 C.P.
2020
Form 944 claiming a $122,665 refund
36

10/30/2022 C.J.
2020
Form 944 claiming a $183,395 refund
37
12/14/2022 Brisk
Carriers
2020
Form 944 claiming a $177,065 refund

all in violation of 18 U.S.C. § 1343.
COUNTS 38-39
Aiding and Assisting in the Preparation of False Tax Returns

50.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
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51.
Between on or about February 1, 2022, and on or about April 1, 2023, in
the Western District of Tennessee and elsewhere, being aided and abetted by
individuals known and unknown to the grand jury, the defendant,
NICOLE JONES
did willfully aid and assist in, procure, counsel, and advise the preparation and
presentation to the Internal Revenue Service, of Form 1040 documents for the
taxpayers and tax periods specified below. The documents were false and fraudulent as
to material matters, in that they represented that the taxpayers were entitled, under the
provisions of the Internal Revenue laws, to claim sick and family leave credits, amongst
other items, that they were not entitled to; whereas defendant JONES then and there
knew the taxpayers were not entitled to claim those items that JONES included on their
tax returns, as described below,
Count # Date
Taxpayer Tax
Period
Falsified Items
38
2/17/2022 N.L.
2021
Refund claim of $15,726 and SFLC
credits on Form 7202
39
3/9/2023
M.H. and
P.H.
2022
Refund claim of $1,114 and SFLC
credits on Schedule H

all in violation of 26 U.S.C. 7206(2).

COUNTS 40-48 – MONEY LAUNDERING
52.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
53.
On or about the dates listed below, in the Western District of Tennessee,
and elsewhere,
RENATA WALTON
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did knowingly engage and attempt to engage in monetary transactions by, through, and
to a financial institution, affecting interstate commerce, in criminally derived property of
a value greater than $10,000, that is, the depositing of cashier’s checks in “The Bank” of
Fayette County, such property having been derived from a specified unlawful activity,
that is, acts of wire fraud under Title 18 U.S. Code, Section 1343, as described in the
chart below,

Count #
Date
Transaction
40
8/25/2022
Deposited a $15,000 cashier’s check from
J.O.T.C. for preparing Form 944 for tax period
2021
41
8/25/2022
Deposited a $15,000 cashier’s check from
B.M.C.C. for preparing Form 944 for tax period
2021
42
9/6/2022
Deposited a $30,000 cashier’s check from M.F.Y.
for preparing Form 944 for tax period 2020
43
9/19/2022
Deposited a $15,000 cashier’s check from T.L.S.
for preparing Form 944 for tax period 2021
44
9/29/2022
Deposited a $15,000 cashier’s check from
B.M.C.C. for preparing Form 944 for tax period
2020
45
9/29/2022
Deposited a $15,000 cashier’s check from
A.L.S.R. for preparing Form 944 for tax period
2021
46
11/28/2022
Deposited a $10,100 from H.H.R. for preparing
Form 944 for tax period 2021
47
12/1/2022
Deposited a $15,000 from G.C. for preparing
Form 944 for tax period 2021
48
12/9/2022
Deposited a $15,000 cashier’s check from T.L.S.
for preparing Form 944 for tax period 2020

 all in violation of 18 U.S.C. § 1957.

COUNTS 49-51 –  MONEY LAUNDERING
54.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
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21

55.
On or about the dates listed below, in the Western District of Tennessee,
and elsewhere, the defendant,
NICOLE JONES
did knowingly engage and attempt to engage in monetary transactions by, through, and
to a financial institution, affecting interstate commerce, in criminally derived property of
a value greater than $10,000, that is, the depositing of cashier’s checks into Renasant
Bank, such property having been derived from a specified unlawful activity, that is,
multiple acts of wire fraud under Title 18 U.S. Code, Section 1343, as described in the
chart below,
Count #
Date
Transaction
49
11/2/2022
Deposited $15,000 cashier’s check from F.L.T. for
preparing Form 944 for tax period 2021
50
11/16/2022
Deposited $15,000 cashier’s check from C.C.S for
preparing Form 944 for tax period 2021
51
7/19/2023
Deposited $15,000 cashier’s check from F.L.T for
preparing Form 944 for tax year 2020

all in violation of 18 U.S.C. § 1957.
COUNT 52 – FAILURE TO FILE
56.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
57.
During Calendar Year 2022, the defendant,
RENATA WALTON
in the Western District of Tennessee, had and received gross income in such an
amount that Walton was required by law, following the close of that calendar year, and
on or before October 16, 2023, on account of Walton’s requesting an extension, to
make an income tax return to the person assigned to receive returns at the local office
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22

of the IRS in the Western District of Tennessee, or at the local office of the IRS in the
Northern District of Mississippi, or to another proper officer of the United States, stating
specifically the items of her gross income and any deductions and credits to which she
was entitled; well knowing and believing the foregoing, Walton, did willfully fail to make
an income tax return;
all in violation of 26 U.S.C. § 7203.

COUNT 53 – FAILURE TO FILE
58.
Paragraphs 1 through 35 are realleged and incorporated by reference as
though fully set forth herein.
59.
During Calendar Year 2022, the defendant,
NICOLE JONES
in the Western District of Tennessee, had and received gross income in such an amount
that Jones was required by law, following the close of that calendar year, and on or
before April 17, 2023, to make an income tax return to the person assigned to receive
returns at the local office of the IRS in the Western District of Tennessee, or at the local
office of the IRS in the Northern District of Mississippi, or to another proper officer of the
United States, stating specifically the items of her gross income and any deductions and
credits to which she was entitled; well knowing and believing the foregoing, Jones, did
willfully fail to make an income tax return;
all in violation of 26 U.S.C. § 7203.

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23

NOTICE OF FORFEITURE ALLEGATIONS
1343, 1349 COUNTS
Upon conviction of Counts 1-16 and 22-28 of this Indictment, the defendant, RENATA
WALTON, shall forfeit to the United States, under Title 18, United States Code, Section
981(a)(1)(C) and Title 28, United States Code, Section 2461(c), all property, real or
personal, which constitutes or is derived from proceeds traceable to the offense.
1343, 1349 COUNTS
Upon conviction of Counts 1 and 30-37, of this Indictment, the defendant, NICOLE
JONES, shall forfeit to the United States, under Title 18, United States Code, Section
981(a)(1)(C) and Title 28, United States Code, Section 2461(c), all property, real or
personal, which constitutes or is derived from proceeds traceable to the offense.
1512(c) COUNT
Upon conviction of Count 29, of this Indictment, the defendant, RENATA WALTON,
shall forfeit to the United States, under Title 18, United States Code, Section
981(a)(1)(C) and Title 28, United States Code, Section 2461(c), all property, real or
personal, which constitutes or is derived from proceeds traceable to the offense.
1957 COUNTS
Upon conviction of Counts 40-48, of this Indictment, the defendant, RENATA WALTON,
shall forfeit to the United States, under Title 18, United States Code, Section 982(a)(1),
all property, real or personal, involved in the offense, and all property that is traceable to
the property involved in the offense.

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1957 COUNTS
Upon conviction of Counts 49-51, of this Indictment, the defendant, NICOLE JONES,
shall forfeit to the United States, under Title 18, United States Code, Section 982(a)(1),
all property, real or personal, involved in the offense, and all property that is traceable to
the property involved in the offense.

A TRUE BILL:

____________________________

F O R E P E R S O N

DATED: November 21, 2024
_

____________________________
REAGAN TAYLOR FONDREN
ACTING UNITED STATES ATTORNEY

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