Complaint — United States v. Rudolph Johnson, Frantz Pasteur and Frederick Anderson (No. 24-10055, D.N.J.)

Summary

A criminal complaint against Rudolph Johnson, a/k/a "Bishop Salis Shwade," Frantz Pasteur and Frederick Anderson, Magistrate No. 24-10055, in the U.S. District Court for the District of New Jersey, attested by IRS Criminal Investigation Special Agent Zvi Wiesenfeld before Hon. Michael A. Hammer on March 13, 2024. Count One charges conspiracy to file false claims under Title 18, United States Code, Section 286, Count Two charges conspiracy to commit wire and mail fraud, and Counts Three to Ten charge money laundering. The affidavit alleges the defendants filed approximately 131 false returns for sham entities claiming COVID-Related Tax Credits, including the Employee Retention Credit. It states they claimed approximately $2,921,060,241.08 in tax benefits and the U.S. Treasury issued approximately $1,027,833.39 in refunds.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cited in: Thirty-Four Cases, Thirty-Three Schemes, No Fraud Rate · Rudolph Johnson

Cite this document

“Complaint — United States v. Rudolph Johnson, Frantz Pasteur and Frederick Anderson (No. 24-10055, D.N.J.).” Original at www.justice.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-no-24-10055-d-n-j-1f9739dd11/, SHA-256 fdf06af6de1c578cea5f3fafabebcc0a703e72b4fa7277e87e9524bf60f3b50b.

Full text

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA : Hon. Michael A. Hammer
:
v. : Magistrate. No. 24-10055
:
RUDOLPH JOHNSON, : CRIMINAL COMPLAINT
a/k/a “Bishop Salis Shwade,” :
FRANTZ PASTEUR, and :
FREDERICK ANDERSON

I, Zvi Wiesenfeld, being duly sworn, state the following is true and correct to
the best of my knowledge and belief:

SEE ATTACHMENT A
I further state that I am a Special Agent with the Internal Revenue Service –
Criminal Investigation and that this complaint is based on the following facts:

SEE ATTACHMENT B
Continued on the attached pages and made a part hereof.

_______________________________
Zvi Wiesenfeld, Special Agent
Internal Revenue Service -
Criminal Investigation

Special Agent Zvi Wiesenfeld attested to this Affidavit by telephone pursuant to
F.R.C.P. 4.1(b)(2)(A) on this 13th day of March 2024.

______________________________
Hon. Michael A. Hammer
United States Magistrate Judge
ATTACHMENT A

COUNT ONE
(Conspiracy to File False Claims Against the Government)

From at least as early as in or around June 2021, through in or around at
least November 2023, in the District of New Jersey, and elsewhere, the defendants,

RUDOLPH JOHNSON,
a/k/a “Bishop Salis Shwade,”
FRANTZ PASTEUR, and
FREDERICK ANDERSON,

did knowingly and intentionally enter into an agreement, combination, and
conspiracy to defraud the United States, or any department or agency thereof, by
obtaining or aiding to obtain the payment or allowance of any false, fictitious or
fraudulent claim.

In violation of Title 18, United States Code, Section 286.

-1-
COUNT TWO
(Conspiracy to Commit Wire and Mail Fraud)

From at least as early as in or around June 2021, through in or around at
least November 2023, in the District of New Jersey and elsewhere, the defendants,

RUDOLPH JOHNSON,
a/k/a “Bishop Salis Shwade,”
FRANTZ PASTEUR, and
FREDERICK ANDERSON,

did knowingly and intentionally conspire and agree to devise and intend 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 940, Forms 941,
Forms 944, and Forms 7200 claiming tax credits, for the purpose of executing and
attempting to execute such scheme and artifice, did transmit and cause to be
transmitted by means of wire communications and mails, in interstate and foreign
commerce, contrary to Title 18, United States Code, Sections 1341 and 1343.

In violation of Title 18, United States Code, Section 1349.

-2-
COUNTS THREE TO TEN
(Money Laundering)

On or about the dates set forth below, in the District of New Jersey and
elsewhere, the defendants,

RUDOLPH JOHNSON,
a/k/a “Bishop Salis Shwade,”
FRANTZ PASTEUR, and
FREDERICK ANDERSON,

did knowingly engage and attempt to engage, in monetary transactions by, through
or to a financial institution, affecting interstate and foreign commerce, in criminally
derived property of a value greater than $10,000, that is, the deposit and transfer of
U.S. currency into bank accounts, such property having been derived from a
specified unlawful activity, that is conspiracy to commit wire and mail fraud in
violation of Title 18, United States Code, Section 1349, and filing fraudulent tax
claims in violation of Title 18, United States Code, Section 286.

Count Approx. Defendant Destination Approximate
Issued Date Amount
3 8/3/2021 JOHNSON Bank Account-1 $770,000
4 8/13/2021 JOHNSON Bank Account-2 $96,000
5 10/25/2022 JOHNSON Bank Account-5 $50,541.56
6 11/2/2021 PASTEUR Bank Account-3 $57.823.27
7 6/21/2022 PASTEUR Bank Account-3 $27,126.04
8 8/3/2021 ANDERSON Bank Account-4 $35,000
9 12/21/2021 ANDERSON Bank Account-4 $35,384.69
10 8/30/2022 ANDERSON Bank Account-4 $42,925.96

In violation of Title 18, United States Code, Sections 1957 and 2.

-3-
ATTACHMENT B

I, Zvi Wiesenfeld, a Special Agent of the Internal Revenue Service, Criminal
Investigation, having conducted an investigation and having discussed this matter
with other law enforcement officers who have participated in this investigation,
have knowledge of the following facts. Because this Complaint is being submitted
for the limited purpose of establishing probable cause, I have not included each and
every fact known to me concerning this investigation. Rather, I have set forth only
the facts that I believe are necessary to establish probable cause. Unless specifically
indicated, all dates described in this affidavit are approximate and all conversations
and statements described in this affidavit are related in substance and in part.

Overview

1. From at least as early as in or around June 2021, through in or around
at least November 2023, Rudolph Johnson a/k/a “Bishop Salis Shwade”
(“JOHNSON”), Frantz Pasteur (“PASTEUR”), and Frederick Anderson
(“ANDERSON” or collectively, the “DEFENDANTS”), exploited a relief
program that was provided for employers under the Coronavirus Aid, Relief,
and Economic Security Act (“CARES Act”). To fraudulently obtain relief, the
DEFENDANTS created fake entities and claimed fraudulent entitlement to
tax refunds on behalf of them. Specifically, the DEFENDANTS submitted
approximately 131 false returns, claiming approximately $2,921,060,241.08
in tax benefits, and obtained approximately $1,027,833.39.

Background

The CARES Act, Employee Retention Credit, and Families First
Coronavirus Response Act

2. The CARES Act, enacted on March 27, 2020, provided for an employee
retention tax credit (“Employee Retention Credit” or “ERC” or “COVID-
Related Tax Credit”), designed to encourage businesses to keep employees on
their payroll. Subsequent legislation (The Taxpayer Certainty and Disaster
Tax Relief Act of 2020 and the American Rescue Plan Act) modified and
extended the ERC.

3. The ERC was a tax credit refundable against certain employment taxes
equal to 50% of the qualified wages an eligible employer paid to employees
after March 12, 2020 and through December 2020. For 2021, the ERC was
refundable against certain employment taxes equal to 70% of the qualified
wages an eligible employer paid to employees from December 31, 2020
through September 2021.

-4-
4. For purposes of the ERC, an eligible employer was a business with operations
that were partially or fully suspended due to governmental orders due to
COVID-19 or a business that had a 50% decline in gross receipts as
compared to the same quarter in 2019.

5. The ERC was capped at $5,000 per employee retained between March 13,
2020 and December 31, 2020, and up to $7,000 per employee per quarter
retained between January 1, 2021 and September 30, 2021.

6. Qualified employers are only eligible to receive the ERC for employees, not
contractors.

7. Qualified employers could access the ERC by reducing upcoming payroll tax
deposits or requesting an advance credit (i.e., a direct refund payment to the
employer), by utilizing the following forms: an “Advance Payment of
Employer Credits Due to COVID-19” form (“Form 7200”); an “Employer’s
Quarterly Federal Tax Return” form (“Form 941”); a “Employer’s Annual
Federal Unemployment Tax Return” form (“Form 940”); and a “Employer’s
Annual Federal Tax Return” form (“Form 944”).

8. IRS Forms 940, 941, 944, and 7200 may be used to claim COVID-Related
Tax Credits. The COVID-Related Tax Credits may be greater than the tax
owed by the employer, resulting in a refund to the employer.

The Defendants and Relevant Entities

9. At all times relevant to this complaint:

a. JOHNSON was a resident of Maplewood, New Jersey.

b. PASTEUR was a resident of Newark, New Jersey.

c. ANDERSON was a resident of Irvington, New Jersey.

d. The following entities were allegedly owned and operated by the
DEFENDANTS: Open Hearts and Spiritual Mind Foundation; The
Urban State Corporation; Urban State of Northern America; Urban
State of Foreign Securities; Urban State of America; The Urban
State; Rudolph K Johnson Jr; OHSMF Charity Holdings; Open
Hearts and Spiritual Mind State Government; Divine Holy See of
Hue Rudolph K Johnson; The Urban State FLLP; Divine Holy See
of Hue; JHS Holdings; Frantz Pasteur Private; Urban State
Washitaw Muurish Government; Clergy Frantz Pasteur; Yochanan
Moorish Enterprises; and Only When Needed Inc.

-5-
Relevant Terms

e. The Internal Revenue Service (“IRS”) was an agency of the United
States Department of Treasury (“U.S. Treasury”) responsible for
the ascertainment, computation, assessment, and collection of
taxes, including employment taxes.

f. A “responsible person” at a business was required to file quarterly
an IRS Form 941—Employer’s Quarterly Tax Return. The
responsible person must supply the IRS with information about the
wages paid by the business, the federal income taxes withheld from
wages, and Social Security and Medicare taxes.

g. IRS Form W-2, Wage and Tax Statement (“W-2”) reports wages
paid by an employer to an employee and taxes withheld from those
wages. It is issued by U.S. employers to employees and is filed by
employers with the Social Security Administration.

Object of the Conspiracy

10. It was a goal of the conspiracy for defendants, JOHNSON, PASTEUR, and
ANDERSON, and others to enrich themselves by exploiting tax benefits,
including COVID-Related Tax Credits that are provided under the CARES
Act. Specifically, the defendants established a slew of sham entities and
filed fraudulent IRS forms in the names of these entities claiming fraudulent
entitlement to tax refunds, including the ERC.

The Scheme to Defraud

11. From at least as early as in or around June 2021 through at least in or
around November 2023, the defendants filed with the IRS approximately 131
tax returns, comprised of Forms 7200, Forms 940, Forms 941, and Forms
944, by mail, fax, or e-file. In total, the defendants claimed approximately
$2,921,060,241.08 in tax benefits, and as a result, the U.S. Treasury issued
approximately $1,027,833.39 in refunds.

12. The false filings were filed on behalf of sham entities. Government records
indicated that these entities had limited tax histories, never paid any W-2
wages, and made only nominal, if any, payments to the IRS.1 Thus, these
entities were ineligible to receive tax refunds, including for COVID-Related

1 The entity, Rudolph K Johnson Jr, made approximately $719.73 in
federal tax deposits during 2020 through 2021 tax periods while reporting deposits
in excess of $5,000,000 to the IRS.

-6-
Tax Credits. A review of government records revealed that the Defendants
were listed as officers of these entities, and thus, were responsible for the
false filings. For instance:

a. Open Hearts and Spiritual Mind Foundation is a New Jersey non-
profit organization that was created on or about January 18, 2019.
According to public filings, Open Hearts and Spiritual Mind
Foundation is a religious organization that assists individuals with
food, shelter, and clothing. JOHNSON was listed as the Chief
Executive Officer, Incorporator, and a Trustee; PASTEUR was listed
as President, Director, and Chairman of the Board; and “Bishop Salis
Schwade” was listed as the Registered Agent for Open Hearts and
Spiritual Mind Foundation.

b. Only When Needed Inc., is a New Jersey non-profit organization that
was created on or about October 9, 2018. According to public filings,
Only When Needed Inc., is engaged in fundraising for cancer research.
ANDERSON was listed as the Incorporator and as a Trustee for Only
When Needed Inc.

c. OHSMF Charity Holding Inc., is a New Jersey non-profit organization
that was created on or about April 27, 2021. According to public
filings, OHSMF Charity Holding Inc., is engaged in “receiving
charitable contributions” and “making investment decisions.”
JOHNSON was listed as the Incorporator and a Trustee; PASTEUR
was listed as a Trustee; and “Bishop Salis Schwade” was listed as the
Registered Agent for OHSMF Charity Holding Inc.

d. Frantz Pasteur Private LLC is a New Jersey company that was created
on or about January 3, 2018. According to public filings, Frantz
Pasteur Private LLC is engaged in financial services. PASTEUR was
listed as the President, Partner, and Chief Executive Officer; and
“Bishop Salis Schwade” was listed as the Registered Agent for Frantz
Pasteur Private LLC.

e. Frederick L. Anderson PLLC is a New Jersey company that was
created on or about January 2, 2018. According to public filings,
Frederick L. Anderson PLLC is engaged in “retail business of all
kinds.” ANDERSON was listed as the Chief Executive Officer,
Partner, and Chairman of the Board; and “Bishop Salis Shwade” was
listed as the Registered Agent for Frederick L. Anderson PLLC.

f. The Urban State FLLP is a New Jersey company that was created on
or about February 16, 2017. According to public filings, The Urban

-7-
State FLLP conducts its business in the United States, the United
Kingdom, and Australia. JOHNSON was listed as an Authorized
Representative for The Urban State FLLP.

g. The Urban State Corporation is a New Jersey non-profit corporation
that was created on or about February 18, 2017. According to public
filings, The Urban State Corporation was formed to help urban
communities with housing development, conduct community events,
provide legal services to prisoners, and work with police powers to
downgrade police brutality. JOHNSON was listed as the Chairman of
the Board for The Urban State Corporation.

h. Time is Money % Rudolph K Johnson Jr is a New Jersey company that
was created on or about November 23, 2022. According to public
filings, Time is Money % Rudolph K Johnson Jr is a music recording
label and performance production company. “Bishop Salis Shwade”
was listed as a Registered Agent and JOHNSON was listed as a
Member/Manager and Authorized Representative for Time is Money %
Rudolph K Johnson Jr.

i. Divine Holy See of Hue is a New Jersey non-profit corporation that
was created on or about October 7, 2022. According to public filings,
The Divine Holy See of Hue is a religious organization that provides
spiritual development. JOHNSON was listed as a member of the
Board of Trustees, Incorporator, and Authorized Signatory, and
ANDERSON was listed as a member of the Board of Trustees for
Divine Holy See of Hue.

13. JOHNSON falsely claimed more than approximately $2,779,011,610.22;
PASTEUR falsely claimed more than approximately $16,573,598.28; and
ANDERSON falsely claimed more than approximately $125,475,032.58 in
tax refunds or credits.

14. In total, the defendants falsely claimed approximately $2,921,060,241.08 in
tax refunds or credits, including for ERCs, as reflected in the chart below (all
figures are approximate):

Approx. Date Period Form Entity Filed By Type Credit/Refund
Received by of Requested
IRS Filing

1. 6/17/2021 201712 944 THE URBAN JOHNSON Mail $70,323.71
STATE FLLP

-8-
2. 6/17/2021 201812 944 THE URBAN JOHNSON Mail $64,876.81
STATE FLLP
3. 6/17/2021 202012 944 THE URBAN JOHNSON Mail $78,109.29
STATE FLLP
4. 6/17/2021 201912 944 CLERGY JOHNSON Mail $74,649.12
RUDOLPH K
JOHNSON JR
5. 6/17/2021 202103 944 RUDOLPH K JOHNSON Mail $22,000.00
JOHNSON JR
6. 6/29/2021 202012 944 OPEN JOHNSON Mail $222,600.00
HEARTS
AND
SPIRITUAL
MIND
FOUNDATIO
N
7. 6/30/2021 201312 944 THE URBAN JOHNSON Mail $50,000,000.00
STATE
CORPORATI
ON
8. 6/30/2021 201412 944 THE URBAN JOHNSON Mail $50,000,000.00
STATE
CORPORATI
ON
9. 6/30/2021 201612 941 THE URBAN JOHNSON Mail $50,000,000.00
STATE
CORPORATI
ON
10. 6/30/2021 201712 944 THE URBAN JOHNSON Mail $50,000,000.00
STATE
CORPORATI
ON
11. 6/30/2021 201812 944 THE URBAN JOHNSON Mail $50,000,000.00
STATE
CORPORATI
ON
12. 6/30/2021 202103 944 THE URBAN JOHNSON Mail $12,500,000.00
STATE
CORPORATI
ON
13. 6/30/2021 202106 944 THE URBAN JOHNSON Mail $12,500,000.00
STATE
CORPORATI
ON

-9-
14. 7/9/2021 201712 941 THE URBAN JOHNSON Mail $102,000,000.00
STATE FLLP
15. 7/9/2021 201812 941 THE URBAN JOHNSON Mail $75,000,000.00
STATE FLLP
16. 7/9/2021 201912 941 THE URBAN JOHNSON Mail $50,000,000.00
STATE FLLP
17. 7/9/2021 202012 941 THE URBAN JOHNSON Mail $50,000,000.00
STATE FLLP
18. 7/9/2021 202103 941 THE URBAN JOHNSON Mail $12,500,000.00
STATE FLLP
19. 11/7/2023 202203 941 TIME IS JOHNSON Mail $1,127,500.00
MONEY %
RUDOLPH K
JOHNSON JR
20. 11/13/2023 202306 941 OPEN JOHNSON Mail $241,740.00
HEARTS
AND
SPIRITUAL
MIND
FOUNDATIO
N
21. 11/7/2023 202303 941 TIME IS JOHNSON Mail $1,127,500.00
MONEY %
RUDOLPH
KIM
JOHNSON JR
22. 11/13/2023 202103 941 TIME IS JOHNSON Mail $5,817,900.00
MONEY %
RUDOLPH
KIM
JOHNSON JR
23. 11/13/2023 202212 941 THE URBAN JOHNSON Mail $1,713,349.00
STATE %
RUDOLPH
KIM
JOHNSON JR
24. 11/13/2023 202109 940 THE URBAN JOHNSON Mail $5,817,900.00
STATE %
RUDOLPH
KIM
JOHNSON JR
25. 11/13/2023 202106 941 THE URBAN JOHNSON Mail $5,817,900.00
STATE %
RUDOLPH

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KIM
JOHNSON JR
26. 11/13/2023 202112 941 THE URBAN JOHNSON Mail $5,817,900.00
STATE %
RUDOLPH
KIM
JOHNSON JR
27. 4/29/2021 202103 940 OPEN JOHNSON E-file $22,008.39
HEARTS
AND
SPIRITUAL
MIND
FOUNDATIO
N INC
28. 7/3/2021 202106 941 URBAN JOHNSON E-file $21,250,000.00
STATE OF
AMERICA
LLP
29. 7/5/2021 202106 941 RUDOLPH JOHNSON E-file $62,542.00
KIM
JOHNSON JR
30. 7/7/2021 202106 941 URBAN JOHNSON E-file $56,100,000.00
STATE OF
AMERICAN
FINANCIAL
SERVICES
LLP
31. 7/7/2021 202106 944 OPEN JOHNSON E-file $770,000.00
HEARTS
AND
SPIRITUAL
MIND
FOUNDATIO
N
32. 8/3/2021 202012 944 THE URBAN JOHNSON E-file $156,000,000.00
STATE OF
AMERICA
FINANCIAL
33. 8/2/2021 202103 941 THE URBAN JOHNSON E-file $6,800,000.00
STATE
34. 8/2/2021 202106 940 THE URBAN JOHNSON E-file $6,800,000.00
STATE
35. 10/1/2021 202109 940 OPEN JOHNSON E-file $9,000,027.00
HEARTS
AND

- 11 -
SPIRITUAL
MIND
FOUNDATIO
N
36. 10/2/2021 202109 941 RUDOLPH JOHNSON E-file $5,000,040.00
KIM
JOHNSON JR
PRIVATE
LTD
LIABILITY
COMPANY
37. 10/5/2021 202012 941 RUDOLPH JOHNSON E-file $4,995,500.00
KIM
JOHNSON JR
PRIVATE
LTD
LIABILITY
COMPANY
38. 10/20/2021 202109 941 THE URBAN JOHNSON E-file $1,207,000.00
STATE OF
AMERICA
FINANCIAL
39. 1/18/2022 202112 941 RUDOLPH JOHNSON E-file $909,140.00
KIM
JOHNSON JR
PRIVATE
LTD
40. 1/18/2022 202112 941 OPEN JOHNSON E-file $959,000.00
HEARTS
AND
SPIRITUAL
MIND
FOUNDATIO
N
41. 4/13/2022 201912 941 THE URBAN JOHNSON E-file $56,100,000.00
STATE FLLP
42. 4/13/2022 202112 941 URBAN JOHNSON E-file $45,010,000.00
STATE
FOREIGN
SECURITIES
43. 4/25/2022 202203 941 URBAN JOHNSON E-file $14,025,000.00
STATE
AMERICA
FINANCIAL
RUDOLPH
JOHNSON JR

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44. 10/18/2022 202012 941 DIVINE JOHNSON E-file $32,700.86
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
45. 10/18/2022 202112 941 DIVINE JOHNSON E-file $524,042.21
HOLY SEE
OF HUE
46. 10/18/2022 202003 941 DIVINE JOHNSON E-file $5,010,231.28
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
47. 10/18/2022 202006 941 DIVINE JOHNSON E-file $5,029,514.48
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
48. 10/18/2022 202009 941 DIVINE JOHNSON E-file $5,038,514.48
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
49. 10/18/2022 202012 941 DIVINE JOHNSON E-file $5,008,514.48
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
50. 10/17/2022 202103 941 DIVINE JOHNSON E-file $5,029,514.48
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
51. 10/17/2022 202106 941 DIVINE JOHNSON E-file $5,029,514.48
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
52. 10/17/2022 202109 941 DIVINE JOHNSON E-file $5,029,514.48
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
53. 10/17/2022 202112 941 DIVINE JOHNSON E-file $5,029,514.48
HOLY SEE

- 13 -
OF HUE
RUDOLPH K
JOHNSON
54. 10/17/2022 202203 941 DIVINE JOHNSON E-file $5,014,754.16
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
55. 10/17/2022 202206 941 DIVINE JOHNSON E-file $5,014,925.84
HOLY SEE
OF HUE
RUDOLPH K
JOHNSON
56. 10/17/2022 202209 941 DIVINE JOHNSON E-file $5,005,681.76
HOLY SEE
OF HUE
57. 11/4/2022 202006 941 OHSMF JOHNSON E-file $9,441,286.55
LEGAL
SERVICES
58. 11/4/2022 202003 941 OHSMF JOHNSON E-file $9,391,286.55
LEGAL
SERVICES
59. 11/4/2022 202112 940 OHSMF JOHNSON E-file $9,391,286.55
LEGAL
SERVICES
60. 11/4/2022 202203 941 OHSMF JOHNSON E-file $9,391,286.55
LEGAL
SERVICES
61. 11/4/2022 202109 941 OHSMF JOHNSON E-file $9,441,286.55
LEGAL
SERVICES
62. 11/4/2022 202012 941 OHSMF JOHNSON E-file $9,441,286.55
LEGAL
SERVICES
63. 11/4/2022 202209 941 OHSMF JOHNSON E-file $9,391,286.55
LEGAL
SERVICES
64. 11/4/2022 202009 941 OHSMF JOHNSON E-file $9,441,286.55
LEGAL
SERVICES
65. 11/4/2022 202206 941 OHSMF JOHNSON E-file $9,391,286.55
LEGAL
SERVICES

- 14 -
66. 11/4/2022 202103 941 OHSMF JOHNSON E-file $9,441,286.55
LEGAL
SERVICES
67. 11/4/2022 202106 941 OHSMF JOHNSON E-file $9,441,286.55
LEGAL
SERVICES
68. 11/15/2022 202209 941 TIME IS JOHNSON E-file $6,260,643.10
MONEY
RUDOLPH K
JOHNSON JR
69. 11/15/2022 202112 941 JHS JOHNSON E-file $1,458,000.43
HOLDINGS
70. 11/22/2022 202003 941 Open Hearts JOHNSON E-file $40,694,180.15
and Spiritual
Mind State
Government
71. 11/22/2022 202006 941 Open Hearts JOHNSON E-file $40,744,180.15
and Spiritual
Mind State
Government
72. 11/22/2022 202009 941 Open Hearts JOHNSON E-file $40,744,180.15
and Spiritual
Mind State
Government
73. 11/22/2022 202012 941 Open Hearts JOHNSON E-file $40,744,180.15
and Spiritual
Mind State
Government
74. 11/22/2022 202103 941 Open Hearts JOHNSON E-file $40,744,180.15
and Spiritual
Mind State
Government
75. 11/22/2022 202106 941 Open Hearts JOHNSON E-file $40,744,180.15
and Spiritual
Mind State
Government
76. 11/22/2022 202109 941 Open Hearts JOHNSON E-file $40,744,180.15
and Spiritual
Mind State
Government
77. 11/22/2022 202112 941 Open Hearts JOHNSON E-file $40,744,180.15
and Spiritual
Mind State
Government

- 15 -
78. 11/22/2022 202203 940 Open Hearts JOHNSON E-file $40,694,180.15
and Spiritual
Mind State
Government
79. 11/22/2022 202209 940 Open Hearts JOHNSON E-file $40,708,129.15
and Spiritual
Mind State
Government
80. 11/22/2022 202206 941 OPEN JOHNSON E-file $40,694,180.15
HEARTS
AND
SPIRITUAL
MIND STATE
GOVERNME
NT
81. 11/27/2022 202203 940 OHSMF JOHNSON E-file $66,860,526.55
Charity
Holdings
82. 11/27/2022 202106 941 OHSMF JOHNSON E-file $66,900,526.55
Charity
Holdings
83. 11/27/2022 202109 941 OHSMF JOHNSON E-file $66,900,526.55
Charity
Holdings
84. 11/27/2022 202112 941 OHSMF JOHNSON E-file $66,900,526.55
Charity
Holdings
85. 11/27/2022 202103 941 OHSMF JOHNSON E-file $66,900,526.55
Charity
Holdings
86. 11/27/2022 202206 941 OHSMF JOHNSON E-file $66,871,686.55
Charity
Holdings
87. 11/27/2022 202209 941 OHSMF JOHNSON E-file $66,860,526.55
Charity
Holdings
88. 1/23/2023 202012 941 OPEN JOHNSON E-file $258,533,600.72
HEARTS
AND
SPIRITUAL
MIND
STATE
GOVERNME
NT

- 16 -
89. 1/23/2023 202112 941 OPEN JOHNSON E-file $258,533,600.72
HEARTS
AND
SPIRITUAL
MIND
STATE
GOVERNME
NT
90. 1/23/2023 202212 944 OPEN JOHNSON E-file $40,285,927.50
HEARTS
AND
SPIRITUAL
MIND
STATE
GOVERNME
NT
91. 1/31/2023 202212 941 OPEN JOHNSON E-file $14,133,600.81
HEARTS
AND
SPIRITUAL
MIND
STATE
GOVERNME
NT
92. 3/1/2023 202009 944 OHSMF JOHNSON E-file $66,900,526.55
CHARITY
HOLDING
93. 3/1/2023 202012 944 OHSMF JOHNSON E-file $66,900,526.55
CHARITY
HOLDING
94. 3/4/2023 202206 944 THE URBAN JOHNSON E-file $4,958,268.00
STATE FLLP
RUDOLPH K
JOHNSON JR
95. 3/4/2023 202212 944 THE URBAN JOHNSON E-file $2,479,134.00
STATE FLLP
RUDOLPH K
JOHNSON JR
96. 3/4/2023 202209 944 THE URBAN JOHNSON E-file $4,338,484.50
STATE FLLP
RUDOLPH K
JOHNSON JR
97. 7/7/2023 202306 944 Open Hearts JOHNSON E-file $433,593.00
and Spiritual
Mind

- 17 -
Foundation
Inc
98. 7/7/2023 202303 944 Open Hearts JOHNSON E-file $433,593.00
and Spiritual
Mind
Foundation
Inc
99. 10/4/2023 202309 944 OPEN JOHNSON E-file $241,740.00
HEARTS
AND
SPIRITUAL
MIND
FOUNDATIO
N
100. 7/12/2021 201812 944 FRANTZ PASTEUR Mail $27,228.00
PASTEUR
PRIVATE
FLLC
101. 7/12/2021 201912 941 FRANTZ PASTEUR Mail $21,000.00
PASTEUR
PRIVATE
FLLC
102. 7/12/2021 202012 941 FRANTZ PASTEUR Mail $45,100.48
PASTEUR
PRIVATE
FLLC
103. 7/12/2021 201712 7200 THE URBAN PASTEUR Mail $235,700.70
STATE
CORPORATI
ON
104. 7/12/2021 201812 941 THE URBAN PASTEUR Mail $270,880.00
STATE
CORPORATI
ON
105. 7/12/2021 201912 941 THE URBAN PASTEUR Mail $320,745.55
STATE
CORPORATI
ON
106. 7/12/2021 202012 941 THE URBAN PASTEUR Mail $132,556.25
STATE
CORPORATI
ON
107. 7/15/2021 202103 941 URBAN PASTEUR Mail $4,675,000.00
STATE OF
AMERICAN

- 18 -
FINANCIAL
SERVICES
LLP
108. 7/12/2021 201712 941 URBAN PASTEUR Mail $110,170.40
STATE
FOREIGN
LLP
109. 7/12/2021 201812 944 URBAN PASTEUR Mail $116,240.00
STATE
FOREIGN
LLP
110. 7/12/2021 201912 941 CLERGY PASTEUR Mail $62,992.40
FRANTZ
PASTEUR
111. 7/12/2021 202103 940 CLERGY PASTEUR Mail $23,520.00
FRANTZ
PASTEUR
112. Not Stated 202106 941 URBAN PASTEUR Mail $8,205,052.00
STATE
WASHITAW
MUURISH
GOVERNME
NT
113. Not Stated 202106 941 FRANTZ PASTEUR Mail $43,200.00
PASTEUR
PRIVATE
FLLC
114. 3/14/2022 202109 941 FRANTZ PASTEUR Mail $79,160.50
PASTEUR
PRIVATE
FLLC
115. 7/3/2021 202106 941 URBAN PASTEUR Fax $2,205,052.00
STATE
WASHITAW
MUURISH
GOVERNME
NT
116. 7/13/2021 202103 941 ONLY WHEN ANDERSON E-file $85,000.00
NEEDED
117. 7/13/2021 202106 941 ONLY WHEN ANDERSON E-file $35,000.00
NEEDED
118. 1/16/2022 202112 941 ONLY WHEN ANDERSON E-file $442,032.00
NEEDED INC

- 19 -
119. 4/18/2022 202112 THE URBAN ANDERSON E-file $50,010,000.00
STATE FLLP
120. 4/25/2022 202203 THE URBAN ANDERSON E-file $55,000,000.00
STATE
CORPORATI
ON
FREDERICK
L
ANDERSON
121. 9/28/2023 202212 FLA Holdings ANDERSON E-file $432,000.58
122. 9/28/2023 202303 FLA Holdings ANDERSON E-file $902,000.00
123. 9/28/2023 202209 FLA Holdings ANDERSON E-file $902,000.00
124. 9/28/2023 202306 FLA Holdings ANDERSON E-file $902,000.00
125. 9/28/2023 202206 FLA Holdings ANDERSON E-file $10,902,000.00
126. 9/28/2023 202203 FREDRICK L ANDERSON E-file $902,000.00
ANDERSON
FLA Holdings
127. 9/28/2023 202212 FREDRICK L ANDERSON E-file $902,000.00
ANDERSON
FLA Holdings
128. 10/4/2023 202309 FLA Holdings ANDERSON E-file $902,000.00
129. 11/13/2023 202303 FLA Holdings ANDERSON Mail $902,000.00
130. 11/16/2023 202303 Frederick L ANDERSON Mail $1,127,500.00
Anderson
FLLC
131. Not Stated 202309 Frederick L ANDERSON Mail $1,127,500.00
Anderson
FLLC

15. A review of JOHNSON’s emails revealed that he had confirmation and
receipt emails from various tax preparation companies for the e-filed IRS
claims in June 2021, July 2021, August 2021, September 2021, October 2021,
January 2022, October 2022, November 2022, January 2023, February 2023,
and March 2023. Additionally, the signatures on all mailed filings appeared
to match the signatures in JOHNSON’s bank documents. Furthermore, the
Internet Protocol Address that is associated with JOHNSON’s mailing
address (“IP Address-1”), was used approximately 187 times to login to
various tax preparation websites from on or about May 14, 2023 through on
or about October 17, 2023.

16. A fingerprint analysis on the return filed on June 7, 2021 for approximately
$23,520 matched the fingerprints of PASTEUR. A review of PASTEUR’s
emails revealed that he had emails containing IRS documents for some of his

- 20 -
entities, including Open Hearts and Spiritual Mind Foundation Inc., and
Frantz Pasteur Private. During the relevant time of the conspiracy, there
were numerous e-mail exchanges between PASTEUR and JOHNSON.

17. From in or around January 2023 through in or around October 2023, the
Internet Protocol Address that is associated with ANDERSON’s mailing
address (“IP Address-2”), was used approximately 19 times to directly
submit tax forms to the IRS and approximately 1,000 times to log in to
various tax preparation websites through which additional returns were
submitted. During the relevant time of the conspiracy, there were numerous
e-mail exchanges between ANDERSON and JOHNSON.

18. As a result of these false claims, the U.S. Treasury issued refund checks to
the sham entities, which in turn were cashed by the DEFENDANTS by
transferring the funds into their respective bank accounts, as outlined below.
In total, the DEFENDANTS received approximately $1,027,833.39 in tax
refunds, including for COVID-Related Tax Credits, to which they were not
entitled, thereby fraudulently enriching themselves, as depicted below (all
figures are approximate):

Approx. Entity Paid to the Destination Refund Issued
Issued Date Order of
8/3/2021 Open Hearts and JOHNSON Bank $770,000
Spiritual Mind Account-1
Foundation
12/28/2021 Open Hearts and JOHNSON Bank $9,031.87
Spiritual Mind Account-1
Foundation
11/2/2021 Frantz Pasteur PASTEUR Bank $57,823.27
Private Account-3
6/21/2022 Frantz Pasteur PASTEUR Bank $27,126.04
Private Account-3
8/3/2021 Only When Only When Bank $35,000
Needed Inc. Needed Inc. Account-4
12/21/2021 Only When Only When Bank $35,384.69
Needed Inc. Needed Inc. Account-4
8/30/2022 Only When Only When Bank $42,925.96
Needed Inc. Needed Inc. Account-4
10/25/2022 Open Hearts and JOHNSON Bank $50,541.56
Spiritual Mind Account-5
Foundation

- 21 -
19. After receiving two checks that were issued to Open Hearts and Spiritual
Mind Foundation, JOHNSON deposited them on or about August 6, 2021
and on or about January 3, 2022, in the amounts of approximately $770,000
and $9,031.87, respectively, into a business bank account for Open Hearts
and Spiritual Mind Foundation (“Bank Account-1”). JOHNSON was listed
as the signatory for Bank Account-1. On or about August 12, 2021,
JOHNSON created another bank account, in his own name, with a zero
balance (“Bank Account-2”), and the following day on or about August 13,
2021, JOHNSON transferred approximately $96,000 from Bank Account-1
into Bank Account-2.

20. On or about August 16, 2021, JOHNSON purchased a Mercedes Benz
(“Mercedes-1”) from a car dealership (“Dealership-1”) with a check from
Bank Account-2 and provided a copy of his driver’s license to Dealership-1.
On or about August 20, 2021, JOHNSON purchased another Mercedes Benz
(“Mercedes-2”) from a different car dealership (“Dealership-2”) with a check
from Bank Account-1 and provided Dealership-2 with a copy of his driver’s
license. Both vehicles2 were registered to the same address as the ones
listed in Bank Account-1 and on JOHNSON’s driver’s license.

21. On or about November 2, 2021 and June 21, 2022, PASTEUR received two
checks that were ultimately deposited to a business bank account for Frantz
Pasteur Private LLC (“Bank Account-3”). Bank Account-3 was opened by
PASTEUR on or about June 22, 2021.

22. On or about August 3, 2021, December 21, 2021, and August 30, 2022,
ANDERSON received three checks that were ultimately deposited to a
business bank account for Only When Needed Inc. (“Bank Account-4”). Bank
Account-4 was opened by ANDERSON on or about July 20, 2020.

23. After receiving a check that was issued to Open Hearts and Spiritual Mind
Foundation, JOHNSON deposited it on or about November 7, 2022, in the
amount of $50,541.56 into a checking account in his name that was opened
on or about April 22, 2022 (“Bank Account-5”).

2 In or around January 2022, ANDERSON and JOHNSON exchanged e-
mails with photos of them posing in front of Mercedes-2. A review of JOHNSON’s
social media accounts also revealed photos of Mercedes-1.

- 22 -
24. In total, the DEFENDANTS, through this scheme, fraudulently caused the
IRS to issue them approximately $1,027,833.39 in tax refunds to which they
were not lawfully entitled.

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File and source

File: complaint-dojatt-1343706-complaint.pdf
Size: 312,965 bytes
SHA-256: fdf06af6de1c578cea5f3fafabebcc0a703e72b4fa7277e87e9524bf60f3b50b
Our copy: complaint-dojatt-1343706-complaint.pdf
Original: www.justice.gov