Information as to Dominic Arthur, United States v. Arthur, No. 2:26-cr-00485 (E.D. Pa.), Doc. 1 (September 29, 2026)

Summary

An Information filed September 29, 2026 as Document 1 in United States v. Dominic Arthur, Case 2:26-cr-00485-CMR, in the United States District Court for the Eastern District of Pennsylvania. Counts One through Six charge mail fraud under 18 U.S.C. § 1341, and Count Seven charges theft of government money under 18 U.S.C. § 641; a notice of forfeiture follows. The information alleges that from in or about February 2022 to in or about 2023 the defendant, with co-schemer Timeeka Loud, filed false Forms 941 seeking COVID-19 related tax credits, sought approximately $1,207,016.13, and caused the IRS to issue six U.S. Treasury checks totaling approximately $1,191,243.42.

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“Information as to Dominic Arthur, United States v. Arthur, No. 2:26-cr-00485 (E.D. Pa.), Doc. 1 (September 29, 2026).” Original at storage.courtlistener.com. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-as-to-dominic-arthur-united-states-v-arthur-no-2-26-cr-004-7d94d58db1/, SHA-256 de36c4a3a2e1c18f0c2ac4406406dec0cc31926d89ea6fcc908f4504a7741b4a.

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Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA : CRIMINAL NO. 26-

v. : DATE FILED:

DOMINIC ARTHUR : VIOLATIONS:
18 U.S.C. § 1341 (mail fraud – 6 counts)
: 18 U.S.C. § 641 (theft of government money
– 1 count)
: Notice of forfeiture

INFORMATION

COUNTS ONE THROUGH SIX
(Mail Fraud)
THE UNITED STATES ATTORNEY CHARGES THAT:

At all times material to this information:

INTRODUCTION

1. Defendant DOMINIC ARTHUR was a resident of Montgomery County,

Pennsylvania.

2. Timeeka Loud, charged elsewhere, was a tax return preparer employed at

a business called TNT Tax Professionals in Philadelphia, Pennsylvania.

3. TH3 GO 2 GUYZ was a limited liability company formed by defendant

DOMINIC ARTHUR in or about December 2020. TH3 GO 2 GUYZ’s purported business was

home remodeling and small construction. Defendant ARTHUR did not report any earnings or

expenses, including wages paid to employees, of TH3 GO 2 GUYZ on any income tax returns

that he filed for tax years 2021 through 2022. Additionally, the Internal Revenue Service (“IRS”)

did not receive an IRS Form W-2 for any employees of TH3 GO 2 GUYZ for these tax years.
Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 2 of 10

The COVID-19 Relief Tax Credits

4. The Coronavirus Aid, Relief, and Economic Security Act (the “CARES

Act”), enacted on March 27, 2020, provided for an employee retention credit (“ERC”) designed

to encourage businesses to retain employees on their payroll during the COVID-19 pandemic.

The Taxpayer Certainty and Disaster Tax Relief Act of 2020 and the American Rescue Plan Act

(“ARPA”) modified and extended the ERC.

5. For calendar year 2020, eligible employers were authorized to claim an

ERC offsetting certain employment taxes that could not exceed 50 percent of up to $10,000 of

qualified wages paid to each employee from March 13, 2020 through December 31, 2020. The

maximum ERC was $5,000 per employee for calendar year 2020. For calendar year 2021,

eligible employers were authorized to claim an ERC offsetting certain employment taxes that

could not exceed 70 percent of up to $10,000 of qualified wages paid to each employee during

each quarter. The maximum ERC was $7,000 per employee per quarter for calendar year 2021.

6. Generally, businesses and tax-exempt organizations that qualified for the

ERC were those that: (a) were shut down during 2020 or the first three calendar quarters of 2021

by government order due to the COVID-19 pandemic; (b) experienced a specified decline in

gross receipts during the eligibility periods during 2020 or the first three calendar quarters of

2021; or (c) qualified as a recovery startup business for the third or fourth quarters of 2021.

7. The Families First Coronavirus Response Act provided for eligible

employers to receive refundable tax credits for wages paid to employees while on sick leave to

recover from any injury, disability, illness, or condition resulting from COVID-19 or wages paid

to employees while on family leave to care for a family member who was injured, disabled, ill,

or otherwise suffering from a condition due to COVID-19. Together these credits were called the

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Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 3 of 10

COVID-19 related tax credits, namely, the ERC and Qualified Sick and Family Leave (“QSFL”)

credit.

8. Employers were entitled to receive a dollar-for-dollar credit for qualified

wages paid to an employee, plus allocable health plan expenses and the employer’s share of

Medicare taxes, while that employee was on sick leave resulting from COVID-19. This credit

was limited to up to ten days of sick leave per employee for the period ending March 31, 2021.

That resulted in a maximum credit of $5,110 per employee for that period. The ARPA provided

an identical credit for the period from April 1, 2021 through September 31, 2021, with an

identical maximum of $5,110 in credits per employee.

9. Employers were also entitled to receive a credit of up to two-thirds of the

qualified wages paid to an employee while that employee was on family leave to care for a

family member suffering from a condition resulting from COVID-19, plus allocable health plan

expenses and the employer’s share of Medicare taxes. For the period ending March 31, 2021, this

credit was limited to up to $200 per day for up to ten weeks, resulting in a maximum eligible

credit of $10,000 per employee. The ARPA provided an identical credit for the period April 1,

2021 through September 30, 2021, and extended the length of family leave to twelve weeks,

thereby raising the maximum eligible credit for that period to $12,000 per employee.

Form 941 Filings

10. COVID-19 related tax credits were claimed by employers by filing an

Employer’s Quarterly Federal Tax Return, Form 941, or an Adjusted Employer’s Quarterly

Federal Tax Return or Claim of Refund, Form 941X (collectively and interchangeably, “Form

941,” “Forms 941,” or “Form 941s”), with the IRS for the relevant quarter or quarters.

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Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 4 of 10

11. Forms 941 reported the business name, its address, and the employer’s

Employer Identification Number (“EIN”), also known as the Federal Employer Identification

Number or the Federal Tax Identification Number. Forms 941 also reported the number of

employees that the business had and the wages paid by the business during that quarter.

12. Critically, in order to qualify for the ERC and related QSFL credit, the

filing business must have paid employees during certain quarters during the COVID-19

pandemic. Moreover, for the QSFL credit, the filing business must have paid sick or family leave

wages. Employers were not eligible to receive both the ERC and QSFL credit with respect to the

same wages.

13. For the COVID-19 related credits, based on the amounts reported on the

Form 941, the U.S. Treasury issued a check in the name of the employer identified on the Form

941 and mailed the check to the employer’s address as it appeared on the Form 941. Each Form

941 represented a separate claim to the government.

14. The IRS relied on the information reported on the Form 941 filed for each

quarter, or for each quarter in the event Form 941 was filed late, about the purported business’

existence, number of employees, and wages paid to the employees to make the credit payments

to employers.

15. Forms 941 could be electronically filed with the IRS using tax preparation

websites, such as, in this case, TaxBandits.

16. . TaxBandits, a legitimate commercially available tax preparation

software, was an online application primarily used to file Forms 941 with the IRS. The

TaxBandits program captured a range of information about each Form 941 user and transaction.

TaxBandits records identified: (i) the nature of each individual activity (e.g., creating an account;

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Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 5 of 10

updating information; adding credit card information; and transmitting to IRS); (ii) the dates and

time stamps of the activity; (iii) the Internet Protocol (“IP”) address from which the activity

originated; and (iv) the type of device and web browser used to access the TaxBandits software.

17. Upon receipt of each Form 941, TaxBandits sent an email to the submitter

of the Form 941 and to the individual/entity that was identified as the employer on each Form

941. These emails included a link for four documents: a copy of the Form 941, a copy of Form

8453 Employment Tax Declaration for an IRS e-file Return, an online filing acceptance letter,

and a receipt for payment of the TaxBandits filing fee.

THE SCHEME

18. From in or about February 2022 to in or about 2023, in the Eastern District

of Pennsylvania, and elsewhere, defendant

DOMINIC ARTHUR,

together with co-schemer Timeeka Loud, devised and intended to devise a scheme to defraud the

IRS and to obtain money and property by means of materially false and fraudulent pretenses,

representations, and promises.

MANNER AND MEANS

It was a part of the scheme that:

19. On or about February 24, 2022, defendant DOMINIC ARTHUR and

Timeeka Loud filed and caused to be filed false Forms 941 for TH3 GO 2 GUYZ TH3 for the

second, third, and fourth quarters of 2021, seeking fraudulent refundable credits. These forms

falsely stated, among other things, that TH3 GO 2 GUYZ had paid wages to five employees.

20. On or about February 25, 2022, defendant DOMINIC ARTHUR and

Timeeka Loud filed and caused to be filed a false Form 941 for TH3 GO 2 GUYZ for the first

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Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 6 of 10

quarter of 2021, seeking fraudulent refundable credits. This form falsely stated, among other

things, that TH3 GO 2 GUYZ had paid wages to five employees.

21. On or about August 29, 2022, defendant DOMINIC ARTHUR and

Timeeka Loud filed and caused to be filed false Forms 941 for TH3 GO 2 GUYZ for the first

and second quarters of 2022, seeking fraudulent refundable credits. These forms falsely stated,

among other things, that TH3 GO 2 GUYZ had paid wages to seven employees.

22. On or about October 24, 2022, defendant DOMINIC ARTHUR and

Timeeka Loud filed and caused to be filed a false Form 941 for TH3 GO 2 GUYZ for the third

quarter of 2022, seeking fraudulent refundable credits. This form falsely stated, among other

things, that TH3 GO 2 GUYZ had paid wages to five employees.

23. In total, over this period, defendant DOMINIC ARTHUR and Timeeka

Loud sought approximately $1,207,016.13 in fraudulent tax refunds in the name of TH3 GO 2

GUYZ.

24. As a result of the filing of the false Forms 941 for the first, second, third,

and fourth quarters of 2021 and the second and third quarters of 2022, defendant DOMINIC

ARTHUR and Timeeka Loud caused the IRS to issue six U.S. Treasury checks totaling

approximately $1,191,243.42 to TH3 GO 2 GUYZ from on or about July 26, 2022, to on or

about November 29, 2022. Pursuant to the information entered on the fraudulent Forms 941, the

IRS mailed these checks to defendant ARTHUR at his business address in King of Prussia,

Pennsylvania.

25. From on or about July 29, 2022, to on or about December 7, 2022,

defendant DOMINIC ARTHUR deposited the fraudulently-obtained U.S. Treasury checks and

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Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 7 of 10

proceeds of the checks into accounts that he controlled at Citizens Bank and JP Morgan Chase

Bank.

26. On or about August 19, 2022, with the proceeds of the U.S. Treasury

checks, defendant DOMINIC ARTHUR transferred approximately $70,100 to co-schemer

Timeeka Loud.

27. From on or about July 29, 2022, to in or about 2023, defendant DOMINIC

ARTHUR used the proceeds of the U.S. Treasury checks to, among other things, pay rent for

expensive apartments, purchase cars and luxury items, and pay travel expenses.

28. On or about the dates set forth below, in Montgomery County, in the

Eastern District of Pennsylvania, and elsewhere, defendant

DOMINIC ARTHUR,

for the purpose of executing the scheme described above, knowingly caused to be delivered by

mail according to the directions thereon, the mailings described below for each count, each

mailing constituting a separate count, delivered from Kansas City, Missouri, to King of Prussia,

Pennsylvania:

Count Tax Approx. Mailing Date of Business Entity Amount of
Period U.S. Treasury Check Check Issued
1 1Q21 7/26/22 TH3 GO 2 GUYZ $252,032.99

2 2Q21 7/26/22 TH3 GO 2 GUYZ $200,289.70

3 3Q21 7/26/22 TH3 GO 2 GUYZ $200,289.70

4 4Q21 7/26/22 TH3 GO 2 GUYZ $200,289.70

5 2Q22 10/4/22 TH3 GO 2 GUYZ $169,123.01

6 3Q22 11/29/22 TH3 GO 2 GUYZ $169,218.32

All in violation of Title 18, United States Code, Section 1341.

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Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 8 of 10

COUNT SEVEN
(Theft of Government Money)

THE UNITED STATES ATTORNEY FURTHER CHARGES THAT:

1. Paragraphs 1 through 17 and 19 through 27 of Count One are incorporated

here.

2. From in or about early 2022 to in or about early 2023, in the Eastern

District of Pennsylvania, and elsewhere, defendant

DOMINIC ARTHUR

stole, purloined, and knowingly converted to his own use a thing of value of the United States in

the amount of over $1,000, that is, six U.S. Treasury checks made payable to TH3 GO 2 GUYZ

totaling approximately $1,191,243.42.

In violation of Title 18, United States Code, Section 641.

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Case 2:26-cr-00485-CMR Document 1 Filed 09/29/26 Page 9 of 10

NOTICE OF FORFEITURE

THE UNITED STATES ATTORNEY FURTHER CHARGES THAT:

1. As a result of the violations of Title 18, United States Code, Sections 1341

and 641, set forth in this information, defendant

DOMINIC ARTHUR

shall forfeit to the United States of America any property, real or personal, constituting, or

derived from, proceeds obtained traceable to such violations, including, but not limited to,

$1,171,143.42.

2. If any of the property subject to forfeiture, as a result of any act or

omission of the defendant:

(a) cannot be located upon the exercise of due diligence;

(a) has been transferred or sold to, or deposited with, a third party;

(b) has been placed beyond the jurisdiction of the Court;

(d) has been commingled with other property which cannot be divided

without difficulty;

it is the intent 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 subject to forfeiture.

All pursuant to Title 28, United States Code, Section 2461(c) and Title 18, United

States Code, Section 981(a)(1)(C).

______________________________
DAVID METCALF
UNITED STATES ATTORNEY

9
No._ _ _ _ _ _ _ _ _ _
UNITED STATES DISTRICT COURT
Page 10 of 10
Eastern District of Pennsylvania
Criminal Division
Filed 09/29/26

THE UNITED STATES OF AMERICA
vs.
DOMINIC ARTHUR
Document 1

INFORMATION
18 U.S.C. § 1341 (mail fraud – 6 counts)
18 U.S.C. § 641 (theft of government money – 1 count)
Case 2:26-cr-00485-CMR

A true bill.
_____________________________________________________________________
Foreperson
Filed in open court this _________________________________day,
Of ________________________A.D. 20_____________
__________________________________________________________________________________________
Foreperson
Bail, $___________________________

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