Supplemental Declaration of John Souza — ERTC Express LLC v. Regulus Group LLC (Southern District of New York)

Summary

The Supplemental Declaration of John Souza, filed November 19, 2025 as Document 44 in ERTC Express LLC versus Regulus Group LLC and XBP Global Holdings, Inc., Case No. 1:25-cv-08490-ER, in the United States District Court for the Southern District of New York. Souza, President and Chief Executive Officer of ERTC Express, supports a motion for reconsideration or, in the alternative, temporary restraints, based on information learned after the November 4, 2025 hearing. The declaration states that TransPecos Bank had terminated its relationship with Exela before that hearing and that ERTC now estimates the IRS tax credit checks in post office boxes Exela controls at approximately $65 million. It states that Exela refused offers to pay for renewing the boxes and to pay the full amount in dispute. Attached forms include IRS Form 8822-B.

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“Supplemental Declaration of John Souza — ERTC Express LLC v. Regulus Group LLC (Southern District of New York).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/44-declaration-john-souza-tro-295c786204/, SHA-256 b5b6fc9b687542602b9865a27c5b0037d4f70c8c466cd55fbefd20ec6317a430.

Full text

Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 1 of 21

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

------------------------------------------------------------- x
:
ERTC EXPRESS LLC, :
:
Plaintiff, :
:
v. : Case No. 1:25-cv-08490-ER
:
REGULUS GROUP LLC and XBP GLOBAL :
HOLDINGS, INC., :
:
Defendants. :
:
------------------------------------------------------------- x

SUPPLEMENTAL DECLARATION OF JOHN SOUZA

1. I, John Souza, submit this supplemental declaration in support of ERTC Express’

motion for reconsideration, or in the alternative, for temporary restraints based on newly

discovered information and respectfully requests the Court to consider these new facts most of

which were learned after the hearing in this matter.

2. I am the President and Chief Executive Officer of Plaintiff ERTC Express

(“ERTC”).

3. I submit this declaration to supplement my earlier declaration with information that

I learned after the November 4, 2025 hearing that shows that the record before the Court at that

time was false and misleading and to inform the Court of events that occurred after the hearing.

4. By way of background, as my colleague and Executive Vice President of ERTC

Brian Anderson explained to the Court, ERTC is a company that was formed to facilitate

applications for employee payroll tax credits pursuant to a statute passed by Congress during the

Covid-19 pandemic. The statute provides that small businesses and other companies that continued

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Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 2 of 21

to employ employees during the pandemic despite being negatively impacted by it are entitled to

payroll tax credits for certain quarters during the pandemic that business employed and paid those

employees.

5. As set forth in the statute, its purpose was to provide assistance as soon as possible

to small businesses who were suffering and that could potentially go out of business as a result of

the pandemic. ERTC was formed to assist businesses who were not able to directly apply for these

tax credits, either because they didn't have the in-house capability and/or they did not have

relationships with outside CPAs or accountants or was referred by CPA’s that did not want to do

or could not do what was necessary to establish entitlement to these refunds. ERTC also obtained

business from CPAs that lacked the specialization to qualify their clients under the ERC

requirements. In order to make it as easy as possible for customers to apply, ERTC gave customers

the choice of whether to pay for the services up front (in which case the IRS tax credit check would

be mailed directly to the customer), or they could choose to pay on the back end and only if the

IRS approved the customer for the tax credit. If the customer chose the second option, ERTC

would receive a portion of any tax credit that was issued and, in that case, the customer would

authorize the tax credit check to be mailed to ERTC’s third party lockbox provider to process the

check and to disburse the funds in accordance with ERTC’s instructions (as authorized by the

customer).

6. As can be seen from the website for ERTC’s related company, FinTitan, which was

also a party to these agreements at issue in this case, one key purpose of creating ERTC was to

establish positive customer relationships with small businesses who would have a need of other

financial services in the future, which ERTC and/or FinTitan would provide. Accordingly, ERTC’s

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Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 3 of 21

current and future relationship with these customers is critical to its business and to the success of

its business plan.

7. As the Court will see from the facts below, ERTC’s goodwill, which is critical to

its success, has been irreparably harmed by the actions of Defendant Exela in this matter. Put

bluntly, Defendant Exela is holding what we believe to be as much as $65 million in IRS tax credit

checks hostage and will not agree to release these checks so that they can be processed as intended

to any of our customers or to us, despite the fact that ERTC has offered to pay the total amount in

dispute that Exela claims to be owed.

8. Further, the ongoing dispute about whether ERTC owes any money at all to Exela

is only tangentially related to ERTC’s seeking of an injunction and/or temporary restraints now.

The parties were aware of the contract dispute for some time. But it was only when Exela informed

ERTC that intended to send the checks back to the IRS that ERTC took immediate action to seek

equitable relief before this Court. In no way did ERTC delay in seeking the injunction – rather, as

soon we faced the threat of imminent irreparable harm, we sought relief here. Further, and as

explained below, after the November 4 hearing, Exela informed ERTC for the first time that it did

not intend to renew the post office boxes and that they would let them lapse (even if ERTC paid

for the cost of renewing them).

9. Information that Exela has presented to this Court at the November 4 hearing on

Plaintiff’s motion for a preliminary injunction was false, misleading and incomplete. Moreover,

events that occurred after the hearing further support the injunctive relief that ERTC seeks.

10. Contrary to the sworn statement of Exela’s President of Bills and Payments

Lakshmi Narayanan Chandramohan, at the time of the hearing, Exela has been terminated from

the Unitco program is was claiming it could use to process checks.

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11. As set forth in more detail in the accompanying supplemental declaration of

TransPecos Bank Chief Executive Officer Michael Kozub, filed herewith, despite the fact that the

record before the Court contained sworn statements that Exela was in a position to perform and

process the checks through its relationship with Transpecos and unitco., Exela knew that statement

was false and misleading as of the day of the hearing.

12. I personally learned in a telephone conversation with a representative of

Transpecos, which occurred after the hearing, that TransPecos Bank had terminated its relationship

with Exela, by email, on the evening of October 31 (more than four days before the November 4

hearing). Until this telephone conversation, I had no knowledge that Exela’s participation in the

Unitco program had been terminated.

13. The fact that Exela’s relationship with TransPecos had been terminated was

concealed from the Court by Exela’s counsel (or at least it was not disclosed).

14. In addition, after the hearing, ERTC and its customers reviewed IRS portals and

other information. This information is incomplete, but it allowed us to estimate the potential

amount of tax credit checks that are being held by Exela. Based on the reconciliations that Exela

provided to us, as of August 2025, they were holding checks in the amount of approximately $9

million. Based on the IRS data that we were able to view, we now estimate that the value of the

tax credit checks in the post office boxes that Exela controls (and that they are refusing to turn

over since August 2025) total approximately $65 million

15. After the November 4 hearing, Exela informed me that it did not intend to renew

the post office boxes. Upon review of our records, ERTC learned that it last paid to renew post

office boxes in November 2024. Therefore, ERTC believes that the post offices boxes will likely

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expire sometime in November 2025 (i.e., within weeks if not days). Exela, for their part, has not

inform ERTC exactly when the post offices boxes need to be renewed by.

16. If the post office boxes are not timely renewed it would result in the checks being

discarded or returned to the IRS. To address this cataclysmic result, ERTC sent a letter to Exela

offering to pay the cost of extending all of these post office boxes for a period of 12 months so that

the parties could work through their disputes without further irreparable harm to the customers.

(See Exhibit A, attached hereto). Exela refused to do so, even though ERTC had agreed to pay

the full amount necessary to do so, and it would not cost Exela a single penny.

17. Exela’s President of Bills and Payments Chandramohan, stated (at paragraph 23 of

her sworn declaration opposing relief) that “If Express cures, its non-payment... [Exela] remains

fully able to perform its services.” But this not true. Exela has refused to turn the checks over,

even if ERTC pays the full amount that it claims to be owed. Following that refusal, ERTC sent

another letter to Exela offering to pay the entire amount in dispute without prejudice, if Exela

would turn over the checks. (See Exhibit B, attached hereto). But Exela refused.

18. ERTC does have (contrary to the record presented to the Court at the November 4

hearing), the power of attorney to act on behalf of its customers, and Exela has always recognized

that fact and acted consistent with that understanding. In fact, Exela has no standing with the IRS

to act in any way related to the customers’ tax credit checks. When opening a new customer

account, ERTC requires every client to execute IRS Form 2848, titled “Power of Attorney and

Declaration of Representative,” appointing ERTC’s CPA employees to act as the customers’

designated representative. A copy of that form is attached hereto as Exhibit C. This form means

that in any dealing, ERTC is empowered by the customer to act on his behalf with respect to any

issues relating to the ERTC tax credits from the IRS, including, but not limited to, submitting

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Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 6 of 21

applications and instructing the IRS where to send the refund checks. ERTC’s CPA associates

then sign IRS form 8822B (on behalf of the customer) which tells the IRS where to send the checks

and a copy of that form is attached hereto as Exhibit D. The IRS recognizes ERTC’s Power of

Attorney and mail any refund checks to the provided address. When ERTC entered into its MSA

agreement with the Exela to act as paymaster and to distribute funds from the IRS refund checks

it filed form 8822B forms on behalf of its customers and directed the IRS to send checks to post

office boxes controlled by Exela so that they could be processed. In addition to the Power of

Attorney provided, the agreement that ERTC signs with all of its customers provides that the

customer is appointing ERTC as its attorney in fact.

19. There is no question that until this motion was filed, the parties at all times

understood and acted as if ERTC had a power of attorney to act on behalf of its customers.

Specifically, Exela signed agreements with ERTC to perform services for ERTC customers. When

two checks bounced as a result of Exela’s problems with its accounts at the Bank of Texas, Exela’s

Vice President of Operations offered to “forward them per your instructions,”, and Exela did

follow ERTC’s instructions. (See Exhibit 4 to the Verified Complaint). Most importantly, between

January 2025 and June 2025 (when Exela had no paymaster accounts), based on instructions from

ERTC, it forwarded over $26 million in customers checks to ERTC without seeking or obtaining

consent from those customers. Accordingly, there is no question that until this motion was filed,

Exela had never once questioned ERTC's power and ability to instruct it, pursuant to the contract,

as to where to send checks and how to process checks on behalf of its customers.

20. Contrary to all of the above, as a result of the fact that a paralegal at one of ERTC’s

predecessor law firms, in the rush to compile the papers to be filed with this Court on an expedited

basis, attached the form IRS Form 8821 which applies to the ability to review documents, rather

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Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 7 of 21

than IRS Form 2848 which clearly states that it is a “power of attorney.” The Court and counsel

became involved in a discussion about that document and whether it constituted a power of

attorney. (T. at 44-45). The accurate record, as set forth herein, which includes many documents

that were before the Court in ERTC’s papers but were not considered, demonstrate unquestionab ly

that both parties understood that ERTC had the power of attorney and that it was acting as the

attorney in fact for its customers, which had never been questioned by Exela until this motion was

filed.

21. Another event that occurred after the November 4 hearing, which further supports

now granting the relief sought, is that ERTC has been contacted by numerous customers (who

were waiting to see if the checks were going to be released based on the result of the preliminary

injunction hearing), have now indicated to ERTC that they intend to file lawsuits against ERTC

(and Exela) for the damages and irreparable harm they are going to suffer as a result of their failure

to obtain access to these checks. This will further destroy ERTC’s hard-earned goodwill with its

customers.

22. All of these lawsuits can likely be prevented if this Court grants the limited relief

sought, which is solely to preserve the checks and for Exela to turn over the IRS tax credit checks

(that it has no legal right to hold) so that they can be delivered to the customers.

23. The Court had previously asked at the November 4 hearing why these checks

cannot be sent to the customers. The simple answer to this is that ERTC financed portions of the

funds spent to operate its business and to apply for these tax credits through banks, including

TransPecos Bank. ERTC also holds UCC liens on these checks. Sending checks to the customers

would be contrary to the settlement statements provided to Exela. Moreover, If these checks were

to be sent to hundreds of small businesses, it would create a chaotic situation where third parties

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Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 8 of 21

and ERTC would have to chase after small businesses to recover the monies that are due to them,

specifically the fee that it advanced for those customers, rather than simply processing those checks

through a different authorized lockbox paymaster (Seacoast), who can promptly deliver the funds

to their rightful sources in accordance with ERTC’s (and their customers’) settlement instructions.

Accordingly, we respectfully submit that the least disruptive and the most equitable solution to

prevent further irreparable harm is for Exela to forward the checks in accordance with the

settlement instructions it now has, and consistent with the status quo under which it previously

forwarded over $26 million in checks to ERTC to be processed in the past.

24. ERTC respectfully prays that this Court consider the true facts that should have

been in front of it at the hearing. Granting this relief will preserve $65 million in IRS tax credit

checks and ensure that they are delivered to the customers – small business who desperately need

the funds to make payroll, to pay ongoing bills, and to ensure that their businesses do not have to

close as a result of the failure to receive the checks. It will also mitigate the irreparable harm which

is occurring to my business, ERTC.

25. I also learned that the IRS has just issued 250 additional customer checks (that

likely total in the tens of millions of dollars) that I believe will be delivered to the post office boxes

that Exela refuses to renew for ERTC.

I declare under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct.

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Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 10 of 21

EXHIBIT A
Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 11 of 21

EXELA/REGULUS/AMERICAS & APAC BARNES & THORNBURG LLP

Srini Murali, President Russell T. Gorkin, Esq.
(Srini.Murali@exelatech.com) (rgorkin@btlaw.com)
2701 East Grauwyler Road 390 Madison Avenue, Floor 12
Irving, TX 75061 New York, NY 10017

Correll Kennedy, Esq. Joel R. Meyer, Esq.
(correll.kennedy@xbpamericas.com) (joel.meyer@btlaw.com)
2701 East Grauwyler Road 2029 Century Park East, Suite 300
Irving, TX 75061 Los Angeles, CA 90067

Dear Mr. Murali, Mr. Kennedy, Mr. Gorkin and Mr. Meyer:

It is our understanding that post office boxes under Exela’s control are due to expire
sometime in the month of November. These post office boxes contain tens of millions of dollars
of IRS tax refund checks issued to ERTC’s customers. We also understand that Exela does not
intend to renew those post office boxes.

Please be advised that nonrenewal of these post office boxes would result in what we
estimate to be approximately $65 million in tax refund checks being returned to the IRS or simply
discarded and that the funds therein will fail to reach the parties required under the settlement
statement that ERTC provided to Exela.

Exela’s actions have already caused tremendous damage and irreparable harm to ERTC
and its customers. If Exela does not renew the post office boxes the damages and irreparable harm
that will be suffered by ERTC and its customers would likely be catastrophic. Accordingly, we
hereby demand and instruct Exela to immediately renew all of the post office boxes that are due
to expire this year for a minimum of one year. To avoid Exela from incurring any further cost or
expense with respect to this renewal demand, ERTC will wire the funds to renew the post office
boxes to your attorneys’ trust account with instructions to your attorneys to forward the funds to
Exela upon receiving the post office’s invoice for the renewals.

In the event Exela does not agree to renew and complete the renewal of these post office
boxes by 5:00 p.m. EST on Monday, November 17, 2025, ERTC will make application to the
Court to enjoin Exela from allowing the post office boxes to expire.

Regards,

John Souza
Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 12 of 21

EXHIBIT B
Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 13 of 21

ERTC Express

NOTICE OF PROPOSAL

November 17, 2025

VIA EMAIL (legalnotices@exelatech.com)

EXELA/REGULUS/AMERICAS & APAC BARNES & THORNBURG LLP

Srini Murali, President Russell T. Gorkin, Esq.
(srini.murali@exelatech.com) (rgorkin@btlaw.com)
2701 East Grauwyler Road 390 Madison Avenue, Floor 12
Irving, TX 75061 New York, NY 10017

Correll Kennedy, Esq. Joel R. Meyer, Esq.
(correll.kennedy@xbpamericas.com) (joel.meyer@btlaw.com)
2701 East Grauwyler Road 2029 Century Park East, Suite 300
Irving, TX 75061 Los Angeles, CA 90067

Re: Terminated - Master Services Agreement dated March 18, 2022

Messrs. Murali, Kennedy, Gorkin and Meyer:

As you are aware, ERTC Express LLC and Kingsland Capital Group LLC d/b/a FinTitan
(“ERTC”) and Regulus Group LLC an Exela Technologies Company (“Exela”) have each
terminated the above-referenced Master Services Agreement (“Agreement”). Exela terminated on
October 14, 2025 (See Verified Complaint, Exb. 10, Email of Taylor Pensoneau); ERTC
terminated on November 3, 2025, for reasons stated in its Notice of Termination. Your client, in
the sworn declaration filed with Court in the Southern District of New York in opposition to our
motion, at paragraph 23, states “If ERTC cures its non-payment… Exela remains fully able to
perform its services.” However, we have learned that on October 31, 2025, TransPecos Bank
terminated Exela’s participation in the Unitco program (Exela’s only banking relationship),
through which Exela could create accounts and deposit customer tax refund checks. The issue
now is the remaining approximately $65 million in IRS tax refund credit checks remaining in
Exela’s control but that belong to ERTC’s clients.

ERTC makes the following proposal for an interim agreement pending the outcome of the
ongoing litigation:

1. ERTC disputes that it owes any money to Exela, but to cure its non-payment it will pay to
Exela the additional sum of $1,158,229.29 as set forth below without prejudice to its rights
to continue to dispute that amount, which constitutes all amounts Exela claims to be owed.
Exela will then perform by reactivating its Beats Workflow Portal so that customers can
access information to prepare their tax returns (which Exela is required to maintain by law).
Exela will also update its Beats system to include all past check images. Exela will also
Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 14 of 21

transmit any and all checks that it is currently holding, including all checks in post office
boxes, to ERTC in the same manner as it did with the approximately $26 million dollars in
tax credit checks in the past. This transfer will occur within (5) calendar days.

2. Exela will renew all post office boxes for 12 months. Upon being presented with an invoice
for the renewal from the U.S. Postal Service, ERTC will pay that invoice. Following the
renewal, and to avoid Exela having to provide further services, Exela will turn over control
of the P.O. boxes to ERTC

3. No other requirements, charges or conditions will be imposed by Exela and no other
payments will be made by ERTC as part of this proposal.

Upon Exela’s acceptance of this offer and to ensure Exela’s performance, ERTC shall
deposit the full amount of the monies owed into its attorney’s trust account. Once Exela
performs and all checks have been received, the funds will be wired to Exela’s attorney’s
trust account. To facilitate transmission of the checks, as it did in the past when Exela
forwarded over $26 million in checks to ERTC for processing, ERTC will hold Exela
harmless from any claims by ERTC’s clients solely for forwarding those checks to ERTC
(even though ERTC holds power of attorney for those customers and Exela has followed
ERTC’s instructions in the past as to where to send checks since the inception of this
contract). No other releases will be given.

This offer expires at 5:00 p.m. EST, on November 18, 2025. Please respond in writing
before that date and time as to whether you accept this offer. Thank you.

John Souza
Founder and CEO
ERTC.com
Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 15 of 21

EXHIBIT C
Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 16 of 21

Form 2848
(Rev. January 2021)
Power of Attorney
and Declaration of Representative
OMB No. 1545-0150
For IRS Use Only
Received by:
Department of the Treasury
▶ Go to www.irs.gov/Form2848 for instructions and the latest information.
Internal Revenue Service Name
Part I Power of Attorney Telephone
Caution: A separate Form 2848 must be completed for each taxpayer. Form 2848 will not be honored Function
for any purpose other than representation before the IRS. Date / /
1 Taxpayer information. Taxpayer must sign and date this form on page 2, line 7.
Taxpayer name and address Taxpayer identification number(s)
1
Daytime telephone number Plan number (if applicable)

hereby appoints the following representative(s) as attorney(s)-in-fact:
2 Representative(s) must sign and date this form on page 2, Part II.
Name and address CAF No. 0311-49865R
Harvey Fisher PTIN P00033888
6200 Dovenshire Ter Telephone No. 817-720-6600
Fort Worth, TX 76112 Fax No. 817-415-0558
Check if to be sent copies of notices and communications X Check if new: Address Telephone No. Fax No.
Name and address CAF No.
PTIN
Telephone No.
Fax No.
Check if to be sent copies of notices and communications Check if new: Address Telephone No. Fax No.
Name and address CAF No.
PTIN
Telephone No.
Fax No.
(Note: IRS sends notices and communications to only two representatives.) Check if new: Address Telephone No. Fax No.
Name and address CAF No.
PTIN
Telephone No.
Fax No.
(Note: IRS sends notices and communications to only two representatives.) Check if new: Address Telephone No. Fax No.
to represent the taxpayer before the Internal Revenue Service and perform the following acts:
3 Acts authorized (you are required to complete line 3). Except for the acts described in line 5b, I authorize my representative(s) to receive and
inspect my confidential tax information and to perform acts I can perform with respect to the tax matters described below. For example, my
representative(s) shall have the authority to sign any agreements, consents, or similar documents (see instructions for line 5a for authorizing a
representative to sign a return).
Description of Matter (Income, Employment, Payroll, Excise, Estate, Gift,
Tax Form Number Year(s) or Period(s) (if applicable)
Whistleblower, Practitioner Discipline, PLR, FOIA, Civil Penalty, Sec.
(1040, 941, 720, etc.) (if applicable) (see instructions)
4980H Shared Responsibility Payment, etc.) (see instructions)

Income 1120, 1120s, 1065, 1041 2020 thru 2025

Payroll 940, 941, 943, 944 2020 thru 2025
Civil Penalties not applicable 2020 thru 2025
4 Specific use not recorded on the Centralized Authorization File (CAF). If the power of attorney is for a specific use not recorded on
CAF, check this box. See Line 4. Specific Use Not Recorded on CAF in the instructions . . . . . . . . . . . . . . ▶

5a Additional acts authorized. In addition to the acts listed on line 3 above, I authorize my representative(s) to perform the following acts (see
instructions for line 5a for more information): XAccess my IRS records via an Intermediate Service Provider;
Authorize disclosure to third parties; Substitute or add representative(s); Sign a return;

Other acts authorized:

For Privacy Act and Paperwork Reduction Act Notice, see the instructions. Cat. No. 11980J Form 2848 (Rev. 1-2021)

Document Ref: J7LPV-KG3QQ-FTE9P-DM5N5 Page 1 of 2
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EXHIBIT D
Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 20 of 21
Change of Address or Responsible Party — Business
Form 8822-B
(Rev. December 2019)
▶Please type or print. OMB No. 1545-1163
▶ See instructions on back. ▶ Do not attach this form to your return.
Department of the Treasury
Internal Revenue Service ▶ Go to www.irs.gov/Form8822B for the latest information.

Before you begin: If you are also changing your home address, use Form 8822 to report that change.

If you are a tax-exempt organization (see instructions), check here

Check all boxes this change affects.
1 X Employment, excise, income, and other business returns (Forms 720, 940, 941, 990, 1041, 1065, 1120, etc.)

2 X Employee plan returns (Forms 5500, 5500-EZ, etc.)

X
3 Business location

4a Business name 4b Employer identification number

5 Old mailing address (no., street, room or suite no., city or town, state, and ZIP code). If a P.O. box, see instructions. If foreign address, also complete spaces
below, see instructions.

Foreign country name Foreign province/county Foreign postal code

6 New mailing address (no., street, room or suite no., city or town, state, and ZIP code). If a P.O. box, see instructions. If foreign address, also complete spaces
below, see instructions.

Foreign country name Foreign province/county Foreign postal code

7 New business location (no., street, room or suite no., city or town, state, and ZIP code). If a foreign address, also complete spaces below, see instructions.

Foreign country name Foreign province/county Foreign postal code

8 New responsible party’s name

9 New responsible party’s SSN, ITIN, or EIN. (CAUTION: YOU MUST REFER TO THE INSTRUCTIONS FOR FORM SS-4 TO SEE WHO MAY USE AN EIN.)

10 Signature. Under penalties of perjury, I declare that I have examined this application, and to the best of my knowledge and belief, it is true, correct, and complete.
Daytime telephone number of person to contact (optional) ▶

Mar 5, 2023

▲▲
Sign Signature of owner, officer, or representative Date
Here Enrolled Agent
Title

Where To File
Send this form to the address shown here that applies to you.

IF your old business address was in . . . THEN use this address . . .

Connecticut, Delaware, District of Columbia, Georgia, Illinois,
Indiana, Kentucky, Maine, Maryland, Massachusetts, Michigan,
Internal Revenue Service
New Hampshire, New Jersey, New York, North Carolina, Ohio,
Kansas City, MO 64999
Pennsylvania, Rhode Island, South Carolina, Tennessee, Vermont,
Virginia, West Virginia, Wisconsin

Alabama, Alaska, Arizona, Arkansas, California, Colorado, Florida,
Hawaii, Idaho, Iowa, Kansas, Louisiana, Minnesota, Mississippi, Internal Revenue Service
Missouri, Montana, Nebraska, Nevada, New Mexico, North Dakota, Ogden, UT 84201-0023
Oklahoma, Oregon, South Dakota, Texas, Utah, Washington,
Wyoming, any place outside the United States

For Privacy Act and Paperwork Reduction Act Notice, see back of form. Cat. No. 57465H Form 8822-B (Rev. 12-2019)
Case 1:25-cv-08490-ER Document 44 Filed 11/19/25 Page 21 of 21
Change of Address or Responsible Party — Business
Form 8822-B
(Rev. December 2019)
Please type or print.
▶
OMB No. 1545-1163
▶ See instructions on back. ▶ Do not attach this form to your return.
Department of the Treasury
Internal Revenue Service ▶ Go to www.irs.gov/Form8822B for the latest information.

Before you begin: If you are also changing your home address, use Form 8822 to report that change.

If you are a tax-exempt organization (see instructions), check here

Check all boxes this change affects.
1 X Employment, excise, income, and other business returns (Forms 720, 940, 941, 990, 1041, 1065, 1120, etc.)

2 X Employee plan returns (Forms 5500, 5500-EZ, etc.)

X
3 Business location

4a Business name 4b Employer identification number

5 Old mailing address (no., street, room or suite no., city or town, state, and ZIP code). If a P.O. box, see instructions. If foreign address, also complete spaces
below, see instructions.

Foreign country name Foreign province/county Foreign postal code

6 New mailing address (no., street, room or suite no., city or town, state, and ZIP code). If a P.O. box, see instructions. If foreign address, also complete spaces
below, see instructions.

Foreign country name Foreign province/county Foreign postal code

7 New business location (no., street, room or suite no., city or town, state, and ZIP code). If a foreign address, also complete spaces below, see instructions.

Foreign country name Foreign province/county Foreign postal code

8 New responsible party’s name

9 New responsible party’s SSN, ITIN, or EIN. (CAUTION: YOU MUST REFER TO THE INSTRUCTIONS FOR FORM SS-4 TO SEE WHO MAY USE AN EIN.)

Mar 5, 2023

▲▲
Sign Signature of owner, officer, or representative Date
Here Enrolled Agent
Title

Where To File
Send this form to the address shown here that applies to you.

IF your old business address was in . . . THEN use this address . . .

For Privacy Act and Paperwork Reduction Act Notice, see back of form. Cat. No. 57465H Form 8822-B (Rev. 12-2019)

File and source

File: 44-declaration-john-souza-tro.pdf
Size: 1,745,914 bytes
SHA-256: b5b6fc9b687542602b9865a27c5b0037d4f70c8c466cd55fbefd20ec6317a430
Our copy: 44-declaration-john-souza-tro.pdf
Original: No public link identified.