Indictment — United States v. Helcio Sperandio (Dkt. 1, D. Mass.)

Summary

A grand jury Indictment in United States v. Helcio Sperandio, Criminal No. 25cr10430, Case 1:25-cr-10430-FDS, in the United States District Court for the District of Massachusetts, filed November 13, 2025. Counts One through Four charge procuring false tax returns under 26 U.S.C. § 7206(2), Counts Five through Eight charge tax evasion under 26 U.S.C. § 7201, and Counts Nine and Ten charge wire fraud under 18 U.S.C. § 1343. The indictment alleges that Sperandio, owner of Aquarelle Painting & Services, Inc., cashed customer checks and failed to report $7,098,171.62 in gross receipts, evading more than $2.3 million in federal income taxes. It alleges that Sperandio obtained a $150,000 EIDL using false gross receipts, later increased to $377,500. The forfeiture section seeks a $377,500 money judgment.

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Case 1:25-cr-10430-FDS Document 1

Filed 11/13/25 Page 1 of 14

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA
v.

HELCIO SPERANDIO,

Defendant

Criminal No. 25cr10430

Violations:

Counts One — Four: Procuring the Preparation ar
Presentation of a False Tax Return
(26 U.S.C. § 7206(2))

Counts Five — Eight: Tax Evasion
(26 U.S.C. § 7201)

Counts Nine — Ten: Wire Fraud
(18 U.S.C. § 1343) |

Forfeiture Allegation:
(18 U.S.C. § 981(a)(1)(C) and

28 U.S.C. § 2461)

INDICTMENT

At all times relevant to this Indictment:

General Allegations

1. HELCIO SPERANDIO lived in Somerville and Chelsea, Massachusetts.

2. SPERANDIO owned and operated Aquarelle Painting & Services, Inc. (“Aquarelle

Painting”), which provided painting services to residential customers.

3. Most of Aquarelle Painting’s customers paid by check.

4, SPERANDIO had at least two business bank accounts for Aquarelle Painting, and

he deposited some customer payment checks into the bank accounts. As described in the table

below, however, SPERANDIO also cashed hundreds of customer checks at a check cashing

business in Medford, Massachusetts:

2018

103

$687,509.60

2019

215

$1,383,380.80
Case 1:25-cr-10430-FDS Documenti - Filed 11/13/25 Page 2 of 14

Number of Checks Amount
2020 286 $1,501,394.35
2021 320 $2,159,944.71
2022 195 $1,576,387.16

5. SPERANDIO used the cash from the checks to pay non-employee workers and

personal expenses.
The Federal Tax Requirements

6. The Internal Revenue Service (“IRS”) was a United States government agency
responsible for the assessment and collection of taxes.

7. SPERANDIO operated Aquarelle Painting as an S Corporation for tax purposes.
Each year, as an S corporation, Aquarelle Painting reported its gross receipts or sales, expenses,
and resulting income or loss to the IRS on a Form 1120-S, U.S. Income Tax Return for an S
Corporation, but did not pay income taxes directly to the IRS. Instead, Aquarelle Painting income
passed through to SPERANDIO, as Aquarelle Painting’s sole shareholder, to report on his personal
income tax return.

8. As an individual taxpayer, SPERANDIO had to report his annual income to the IRS
on a Form 1040, U.S. Individual Income Tax Return, and pay any tax due and owing.

Tax Evasion and False Tax Returns

9. Starting no later than 2018, SPERANDIO used a tax preparer to prepare and to file
the annual Form 1120-S for Aquarelle Painting and to prepare and to file his personal Form 1040.
10. For the purpose of preparing the Forms 1120-S and 1040, SPERANDIO gave his
tax preparer online access to Aquarelle Painting’s bank accounts, but SPERANDIO did not give
his tax preparer any information about the hundreds of checks that he cashed each year at the

Medford check cashing business.
Case 1:25-cr-10430-FDS Documenti - Filed 11/13/25 Page 3of 14

11. Asaresult, for each tax year, the tax preparer prepared a Form 1120-S for Aquarelle
Painting that did not include the gross receipts, and therefore income, from the hundreds of cashed
checks. The tax preparer transferred business income from the Form 1120-S to SPERANDIO’s
Form 1040, which, accordingly, also failed fully to report SPERANDIO’s annual income from the
operation of Aquarelle Painting.

12. Each year, after preparing returns, the tax preparer verbally reviewed Aquarelle
Painting’s Form 1120-S and SPERANDIO’s Form 1040 with SPERANDIO and obtained from
SPERANDIO verbal authorization to file the returns electronically as well as a signed authorization
for the tax preparer to file the returns electronically.

13. Specifically, for each year’s Form 1120-S e-filing from 2018 through 2021,
SPERANDIO signed and gave his tax preparer a Form 8879-S, IRS e-file Signature Authorization
for Form 1120-S, which included an attestation under penalties of perjury that SPERANDIO had
examined the corporation’s electronic income tax return and that “to the best of [his] knowledge
and belief, it was true, correct, and complete.” Each year’s Form 8879-S also included (at Line 1)
the gross receipts or sales for Aquarelle Painting that appeared on Line 1c on the company’s Form
1120-S for that year.

14. For tax year 2022, SPERANDIO signed and gave his tax preparer a Form 8879-
CORP, E-file Authorization for Corporations. This form also included an attestation under
penalties of perjury that the 2022 Form 1120-S for Aquarelle Painting was true and correct, and
although it did not include the gross receipts from the Form 1120-S, it did include “Total Taxable
Income” from Line 6 of the Form 1120-S.

15. Similarly, for each year’s Form 1040 e-filing, SPERANDIO signed a Form 8879,

IRS e-file Authorization, which included a statement under penalties of perjury that the Form 1040
was “true, correct, and complete.” The Form 8879 also included (at Line 1) the adjusted gross
income from the Form 1040.

16. | With SPERANDIO’s authorization, the tax preparer e-filed each year’s Form 1120-
S with the IRS, unwittingly underreporting Aquarelle Painting’s gross receipts. At
SPERANDIO’s request, the tax preparer later e-filed amended returns for tax years 2020 and 2021,
which also did not report Aquarelle Painting’s gross receipts from cashed customer checks.

17. From 2019 through 2022, Aquarelle Painting’s actual gross receipts were steady,
and even went up in 2021, but SPERANDIO reported decreasing gross receipts each year. In total,
SPERANDIO failed to report $7,098,171.62 in gross receipts to the IRS on his Forms 1120-S, as

follows:

Form 1120-S_— Filed On Or About

Gross Receipts on Line le Actual Gross Receipts

2018 April 24, 2019 $1,105,740 $1,742,839.60
2019 March 15, 2020 $440,448 $1,757,473.80
Amended February 21, 2023 $276,179 $1,745,791.35
2020 (Amended)
Amended February 21, 2023 $175,586 $2,276,550.71
2021 (Amended)
2022 April 28, 2023 $132,452 $1,701,539.16

18. The tax preparer also e-filed each year’s Form 1040 with the IRS to report
SPERANDIO’s income (or loss) and tax liability from the operation of Aquarelle Painting.
19. Asaresult, from 2018 through 2022, SPERANDIO evaded more than $2.3 million

in federal income taxes, as follows:

2018 $11,449 $220,351 $208,902
2019 $691 $428,913 $428,222
2020 (Not Filed) $0 $458,129 $458,129
2021(Amended) $4,091 (Refund) $697,866 $701,957
2022 $0 $512,257 $512,257
Case 1:25-cr-10430-FDS Document1i - Filed 11/13/25 Page5of14

The Scheme to Defraud the Small Business Administration

20. The United States Small Business Administration (“SBA”) was an executive
branch agency of the United States government that provided support, including government-
backed loans, to qualifying small businesses.

21. The Economic Injury Disaster Loan (“EIDL”) program was an SBA program that
provided low-interest financing to small businesses, renters, and homeowners affected by declared
disasters. The Coronavirus Aid, Relief, and Economic Security Act and Coronavirus Response
and Relief Supplemental Appropriations Act authorized the SBA to issue EIDLs to small
businesses adversely affected by the Coronavirus pandemic and associated mitigation measures.

22. To obtain an EIDL, a qualifying business had to submit an application to the SBA
and provide information about business operations, such as the number of employees, gross
revenues for the 12-month period preceding the disaster, and the business’s cost of goods sold in
the 12-month period preceding the disaster. In the case of EIDLs for COVID-19 relief, the
relevant 12-month period was the year preceding January 31, 2020.

23. An EIDL applicant also had to certify that all of the information the applicant
submitted was true and correct to the best of the applicant’s knowledge and to attest to certain
threshold eligibility requirements set by federal regulation, including that the applicant was “not
engaged in any illegal activity.” See 13 C.F.R. § 123.201(d).

24. The SBA received EIDL applications and related documents electronically through
servers located outside Massachusetts, including in Iowa.

25. The SBA determined the amount of an approved EIDL based on information the

applicant provided about employment, revenue, and cost of goods, as described above.
26. A business receiving an EIDL loan could only use EIDL funds to alleviate specific
economic injury from the COVID-19 pandemic.

The Fraudulent EIDL Loan

27. By April 2020, SPERANDIO had been evading income taxes that he should have
paid based on Aquarelle Painting’s gross receipts for more than two years.

28. By April 2020, SPERANDIO had also been filing false Massachusetts tax returns
for Aquarelle Painting that reported the same false information from Aquarelle Painting’s false
Forms 1120-S.

29. No later than on or about April 3, 2020, approximately two weeks after filing a false
Form 1120-S for Aquarelle Painting for tax year 2019 in order to evade approximately $428,222 in
federal income taxes, SPERANDIO submitted a false and fraudulent application to obtain an EIDL
loan to Aquarelle Painting from the SBA. Specifically, on his application, SPERANDIO attested
under penalties of perjury that he was “not engaged in any illegal activity” and that the company’s
gross receipts for 2019 were $1,105,740, the false amount that appeared on his Form 1120-S for
2018.

30. | Onor about June 2, 2020, SPERANDIO executed by DocuSign an agreement with
the SBA for an EIDL loan in the amount of $150,000.

31. On or about the same day, from a computer in Massachusetts, SPERANDIO
transmitted the DocuSign verification for his EIDL loan agreement to an SBA computer in Iowa.

32. On or about June 3, 2020, SPERANDIO received $149,900 in EIDL funds from the

SBA into an Aquarelle Painting bank account (the “3799 Account”).
The Fraudulent EIDL Loan Increase

33. On or about October 21, 2021, SPERANDIO electronically contacted the SBA
about increasing the amount of his EIDL loan.

34. As part of that loan increase process, on or about the same day, SPERANDIO
transmitted DocuSign credentials from a computer in Massachusetts to the SBA’s computer in
Iowa.

35. | Onor about November 1, 2021, the SBA notified SPERANDIO that his request for
a loan increase had been approved and that his loan amount would be increased from $150,000 to
$377,500.

36. | Onor about the same day, SPERANDIO executed by DocuSign an agreement with
the SBA for an EIDL loan increase of his prior loan to the amount of $377,500. In the loan increase
agreement, SPERANDIO certified under penalties of perjury, among other things, that his initial
loan application and all supplementary materials were “true, correct, and complete” and that he
would “use all the proceeds of this Loan solely as working capital to alleviate economic injury
caused by the [Covid-19] disaster.”

37. On or about the same day, SPERANDIO transmitted DocuSign credentials for the
new loan agreement from a computer in Massachusetts to the SBA’s computer in Iowa.

38. On or about November 5, 2021, the SBA transferred $277,500 into the 3799
Account, which, after the deposit, had a balance of $228,210.50.

39. From on or about November 5, 2021 to on or about January 3, 2022, SPERANDIO
deposited no more than about $28,130.17 into the 3799 Account.

40. On or about November 11, 2021, SPERANDIO created a new business, Aquarelle

Properties, LLC, to buy and sell, to manage and lease, and to develop real estate properties.
41. On or about January 3, 2022, SPERANDIO withdrew $130,000 from the 3799
Account, opened a new account in the name of Aquarelle Properties LLC (the “9634 Account”),

and deposited $130,000 into the 9634 Account, to fund the operation of SPERANDIO’s new real

estate company.
Case 1:25-cr-10430-FDS Documenti Filed 11/13/25 Page 9 of 14

COUNTS ONE — FOUR

Procuring the Preparation or Presentation of a False Tax Return

(26 U.S.C. § 7206(2))

The Grand Jury charges:

42. The Grand Jury re-alleges and incorporates by reference paragraphs 1 to 41 of this

Indictment.

43. On or about the dates listed below, in the District of Massachusetts, the defendant,

HELCIO SPERANDIO

willfully aided and assisted in, and procured, counseled, and advised the preparation and

presentation to the Internal Revenue Service of U.S. Income Tax Returns for an S Corporation,

Form 1120-S, for Aquarelle Painting & Services, Inc., as described in the table below, that were

false and fraudulent as to a material matter, to wit: each tax return failed to report the gross

receipts or sales that derived from customer checks that the defendant cashed.

4 3/15/2020 _| Filed 2019 Form 1120-S, reporting $440,448 in gross receipts _
2 4/5/2021 Filed 2020 Form 1120-S, reporting $276,197 in gross receipts
3 2/21/2023 Filed Amended 2021 Form 1120-S, reporting $175,586 in gross receipts
4 4/28/2023 Filed 2022 Form 1120-S, reporting $132,452 in gross receipts

All in violation of Title 26, United States Code, Section 7206(2).
Case 1:25-cr-10430-FDS Document1 Filed 11/13/25 Page 10 of 14

COUNTS FIVE — EIGHT
Tax Evasion
(26 U.S.C. § 7201)

The Grand Jury charges:

4A.

The Grand Jury re-alleges and incorporates by reference paragraphs 1 to 41 of this

Indictment.

45.

From in or about 2019 through in or about 2022, in the District of Massachusetts,

the defendant,

HELCIO SPERANDIO,

willfully attempted in any manner to evade and defeat income tax due and owing by him to the

United States of America for the tax years 2018 to 2022 by committing the following affirmative

acts in each year, among others:

a.

Cashing customer payment checks instead of depositing them into Aquarelle Painting
& Services, Inc. bank accounts;

Paying contractors of Aquarelle Painting & Services, Inc. and personal expenses in
cash;

Providing his tax preparer with bank account records to calculate gross receipts for
Aquarelle Painting & Services, Inc., but not providing his tax preparer with any record
of or information about the customer payment checks that he cashed;

Certifying the accuracy of the Forms 1120-S, U.S. Income Tax Return for an S
Corporation, that his tax preparer prepared for Aquarelle Painting & Services, Inc., as
described in the table below;

Certifying the accuracy of the Forms 1040, U.S. Individual Tax Return, that his tax
preparer prepared for him and for his spouse; and

Causing his tax preparer to file income tax returns that fraudulently underreported his

10
Case 1:25-cr-10430-FDS Document1 Filed 11/13/25 Page 11 of 14

income from Aquarelle Painting & Services, Inc.

3/18/2020

Attestation on Form 8879-S for e-filing Form 1120-S for 2019

6 3/24/2021 Attestation on Form 8879-S for e-filing Form 1120-S for 2020
7 4/22/2022 Attestation on Form 8879-S for e-filing Form 1120-S for 2021
8 11/20/2023 _| Attestation on Form 8879-CORP for e-filing Form 1120-S for 2022

All in violation of Title 26, United States Code, Section 7201.

11
Case 1:25-cr-10430-FDS Document1 Filed 11/13/25 Page 12 of 14

COUNTS NINE AND TEN
Wire Fraud
(18 U.S.C. § 1343)

The Grand Jury charges:

46. The Grand Jury re-alleges and incorporates by reference paragraphs 1 to 41 of this
Indictment.

47. On or about the dates listed below, in the District of Massachusetts and elsewhere,
the defendant,

HELCIO SPERANDIO

having devised and intending to devise a scheme and artifice to defraud, and for obtaining money
and property by means of materially false and fraudulent pretenses, representations, and promises,
did transmit and cause to be transmitted by means of wire communications in interstate and foreign
commerce, writings, signs, signals, pictures, and sounds for the purpose of executing the scheme
to defraud the United States Small Business Administration’s Economic Injury Disaster Loan

program, as set forth below:

9 6/2/2020 Credential from Massachusetts to Iowa for $150,000 EIDL loan
10 10/21/2021 | Credential from Massachusetts to Iowa for $227,500 loan increase

All in violation of Title 18, United State Code, Section 1343.

12
Case 1:25-cr-10430-FDS Document1 Filed 11/13/25 Page 13 of 14

FORFEITURE ALLEGATION
(18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c))

The Grand Jury further finds:
48. The Grand Jury re-alleges and incorporates by reference paragraphs 1 to 41 of this
Indictment.
49. Upon conviction of one or more of the offenses in violation of Title 18, United
States Code, Section 1343, set forth in Counts Nine and Ten, the defendant,
HELCIO SPERANDIO
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C),
and Title 28, United States Code, Section 2461(c), any property, real or personal, which
constitutes or is derived from proceeds traceable to the offenses. The property to be forfeited
includes, but is not limited to, the following asset(s):

a. $377,500 in United States currency, to be entered in the form of a forfeiture
money judgment.

50. If any of the property described in Paragraph 49, above, as being forfeitable
pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code,
Section 2461(c), as a result of any act or omission of the defendant(s) --

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided without
difficulty;

13
Case 1:25-cr-10430-FDS Document1 Filed 11/13/25 Page 14 of 14

it is the intention of the United States, pursuant to Title 28, United States Code, Section 2461(c),
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property
of the defendant up to the value of the property described in Paragraph 49 above.

All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United

States Code, Section 2461(c).

A TRUE BILL

FOREPERSON

KRISS BASIL
ASSISTANT UNITED STATES ATTORNEY

DISTRICT OF MASSACHUSETTS

District of Massachusetts: November _/ 5, 2025
Returned into the District Court by the Grand Jurors and filed.

14


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