Information — United States v. Charles D. Katz, District of Massachusetts (Document 1)

Summary

A criminal information in United States of America v. Charles D. Katz, Criminal No. 1:25-cr-10407-LTS, filed October 20, 2025 as Document 1 in the U.S. District Court for the District of Massachusetts. Count One charges conspiracy to defraud the United States under 18 U.S.C. § 371, and Counts Two and Three charge loan fraud under 18 U.S.C. § 1014. The information alleges that Katz, a Certified Public Accountant who owned CD Katz LLC and co-owned Gebsco Realty Corporation, agreed with a co-conspirator to pay that person off the books, avoiding reporting at least $1,668,487 and causing a tax loss of at least $835,105. It alleges that in 2020 Katz falsely certified on pandemic relief applications that he was not engaged in federal crimes, and that the companies received a total of $179,900. The signature block names United States Attorney Leah B. Foley.

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

Cite this document

“Information — United States v. Charles D. Katz, District of Massachusetts (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-united-states-v-katz-dkt-1-d-mass-d675044bc8/, SHA-256 2c6900d342a92bf19dc543a97d8cd219fe461521cf0b2a786f4f338ea42fac2b.

Full text

Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 1 of 15

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA Criminal No. 25cr10407
v. Violations:
CHARLES D. KATZ Count One: Conspiracy to Defraud the
United States
Defendant (18 U.S.C. § 371)

Counts Two and Three: Loan Fraud
(18 U.S.C. § 1014)

Conspiracy to Defraud Forfeiture Allegation:
(18 U.S.C. § 982(a)(2))

Loan Fraud Forfeiture Allegation:
(18 U.S.C. § 981(a)(1)(C) and 28 U.S.C.
§ 2461)

INFORMATION

At all times relevant to this Information:

General Allegations

1. Defendant CHARLES D. KATZ lived in Sudbury, Massachusetts, where he

worked as a Certified Public Accountant. He owned CD Katz LLC (“CDK”), a firm that provided

financial advice and tax preparation services to businesses and individuals, and co-owned Gebsco

Realty Corporation (“Gebsco”), a real estate investment and management company.

2. Co-conspirator 1 (“CC-1”) lived in Marlborough, Massachusetts. Starting no later

than about 2013, CC-1 worked at CDK as the Director of Corporate Services and purportedly

earned between $51,200 and $81,000 annually from 2013 to 2023. Starting no later than 2013,

CC-1 also worked for Gebsco as its Chief Operating Officer, but until 2023, CC-1 was not on

Gebsco’s payroll.

1
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 2 of 15

3. No later than about 2014, CC-1 and KATZ agreed that CDK and Gebsco would

compensate CC-1 off the books by, among other things, paying members of CC-1’s family,

providing rent-free housing to his family, paying for his children’s college tuition, and paying for

personal expenses that CC-1 and a family member charged on Gebsco’s and CDK’s corporate

credit cards.

4. KATZ hid CC-1’s true compensation by not reporting it on CDK’s or Gebsco’s

income or employment tax filings and by not issuing any Form W-2 or Form 1099 to CC-1 that

accurately recorded CC-1’s actual taxable compensation.

5. CC-1 hid his true compensation by filing false personal income tax returns.

6. Through this scheme, KATZ and CC-1 avoided reporting at least $1,668,487 in off-

the-books compensation to CC-1 to the Internal Revenue Service (“IRS”). As a result, CC-1 and

KATZ did not pay income and employment taxes on CC-1’s true compensation and caused the

IRS and the Commonwealth of Massachusetts to suffer a tax loss of at least $835,105.

7. In 2020, when the COVID-19 pandemic broke out, KATZ applied for pandemic

relief loans for CDK and Gebsco. In each instance, KATZ falsely certified, despite being engaged

in a multi-year tax fraud, that he was not engaged in federal crimes. Based on KATZ’s false

certifications, CDK and Gebsco fraudulently received a total of $179,900 in pandemic relief funds.

KATZ used at least some of the proceeds to fund CC-1’s off-the-books compensation.

Obligations to the Internal Revenue Service

8. The IRS was responsible for administering and enforcing the tax laws of the United

States, collecting taxes owed by its citizens and businesses to the United States Treasury, and

providing refunds of overpaid taxes.

9. Domestic corporations generally were required to file annual income tax returns,

2
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 3 of 15

regardless of whether they had any taxable income, either as S Corporations or C Corporations.

10. S Corporations were closely held companies that chose to be taxed under

Subchapter S of Chapter 1 of the Internal Revenue Code. S Corporations were required to file

annual United States Income Tax Returns for S Corporations Form 1120S (“Form 1120S”) to

report their annual gross receipts or sales, expenses, and resulting income or loss. Deductible

expenses included, among other things, employee salaries and wages; pensions and profit-sharing

plans; and employee benefit programs. S Corporations could elect to “pass through” any profits

or losses to their shareholders for federal tax purposes. Such shareholders were then required to

include their share of an S Corporation’s income or loss on their individual income tax return,

Form 1040, using a “Schedule K-1” and to pay any tax due as a result.

11. C Corporations were required to file annual United States Corporations Income Tax

Returns, Form 1120 (“Form 1120”) to report the income; deductions, gains, and losses from their

operations. Deductible expenses included, among other things, employee salaries and wages;

pensions and profit-sharing plans; and employee benefit programs. C Corporations were taxed

separately from their owners.

12. Limited Liability Companies (“LLCs”) were entities created by state statute. The

IRS treated LLCs either as corporations, partnerships, or as part of their owners’ tax returns (a

“disregarded entity”), depending on the LLCs’ size and its members’ elections. For income tax

purposes, LLCs with only one member were treated as entities disregarded as separate from their

owners, unless the LLCs filed Form 8832 and affirmatively elected to be treated as corporations.

If single-member LLCs did not elect to be treated as corporations, the LLCs were “disregarded

entities,”, and their activities had to be reflected on their owners’ federal tax returns. If the owners

were individuals, the LLCs’ activities were generally reflected on Form 1040 Schedule C, Profit

3
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 4 of 15

or Loss from Business (“Form 1040 Schedule C”).

CDK & Gebsco

13. CDK filed its taxes on KATZ’s Form 1040 Schedule C.

14. Before 2016, Gebsco filed its taxes as a C Corporation using Form 1120. After

2016, Gebsco filed its taxes as an S Corporation using Form 1120S.

FICA Taxes

15. The tax code required businesses to withhold certain taxes from their employees’

paychecks and pay those taxes over to the IRS. These federal employment taxes consisted of

federal income tax and Federal Insurance Contribution Act taxes (“FICA taxes”).

16. In general, the tax code required employers to deduct and withhold income taxes

on the amount of wages actually or constructively paid to employees and to pay over those

withholding taxes to the IRS.

17. FICA taxes consisted of two elements: Social Security taxes, which were used to

fund retirement and disability benefits, and Medicare taxes, which were used to provide health and

medical benefits for the aged and disabled. Employers were required to deduct and withhold

FICA taxes on the amount of wages actually or constructively paid to employees and to pay over

those FICA taxes to the IRS. Employers were also responsible for paying their own FICA taxes

based on the wages paid to their employees. The employee portion of FICA taxes, along with

federal withholding taxes, were collectively referred to as “Trust Fund Taxes.” Trust Fund Taxes

and the employer's matching FICA taxes were collectively referred to as “employment taxes.”

18. Federal tax law required employers to file Form 941s, Employers Federal Quarterly

Tax Returns (“Form 941”), which employers used to report and pay all Federal payroll taxes.

Federal tax law required employers to file Form 941 four times per year, one for each quarter

4
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 5 of 15

ending March 31, June 30, September 30, and December 31. Employers were required to pay

over payroll taxes to the IRS, in full, by the due date of the Form 941.

19. Section 7501 of the Internal Revenue Code provided that whenever any person was

required to withhold or collect any internal revenue tax from any other person and to pay over such

tax to the United States, the amount of tax so withheld or collected was to be held in trust on behalf

of the United States.

20. In addition, employers were generally to file and provide to employees a United

States Wage and Tax Statement, Form W-2 (“Form W-2”), to report, among other things, total

wages, tips, and other compensations, including fringe benefits, and to report income tax withheld

from employees and paid to the IRS.

21. In addition, employers were generally required to file and provide Forms 1099 to

any independent contractor to whom the employer paid more than $600.

22. Any individual who was employed in the United States and earned income during

a calendar year in excess of a threshold amount, was obligated to file a United States Individual

Income Tax Return, Form 1040 (“Form 1040”) with the IRS for that calendar year and was

required to report earnings recorded on Form W-2 and on Form 1099, in addition to other earnings.

23. All Forms 941, 1040, 1120, and 1120S required the filer to sign an attestation under

penalty of perjury that the return and accompanying schedules were true, correct, and complete.

24. KATZ was responsible for accurately collecting, accounting for, and paying taxes

over to the IRS. He was also responsible for preparing, and causing to be prepared, accurate

business Income Tax Returns (Form 1040 Schedule C, Form 1120 or 1120S) and payroll tax

returns (Form 941) for CDK and Gebsco and for issuing Forms W-2 and 1099 to employees and

independent contractors of both companies.

5
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 6 of 15

25. CC-1 was responsible for accurately reporting his taxable income to the IRS and

paying all taxes due and owing.

The Paycheck Protection Program

26. The Paycheck Protection Program (“PPP”) was a COVID-19 pandemic relief

program administered by the Small Business Administration (“SBA”) that provided forgivable

loans to small businesses for job retention and certain other expenses. The PPP permitted

participating third-party lenders to approve and disburse SBA-backed PPP loans to cover payroll,

fixed debts, utilities, rent/mortgage, accounts payable and other bills incurred by qualifying

businesses during, and resulting from, the COVID-19 pandemic.

27. To obtain a PPP loan, a qualifying business had to submit a PPP loan application,

signed by an authorized representative of the business. The PPP loan application required the

business (through its authorized representative) to acknowledge the program rules and make

certain affirmative certifications to be eligible to obtain the PPP loan, including that the business

was in operation and either had employees for whom it paid salaries and payroll taxes or paid

independent contractors and that the applicant was “not engaged in any activity that is illegal under

federal, state or local law.” A business applying for a PPP loan was required to provide

documentation showing its payroll expenses, such as filed federal income tax documents.

28. PPP loan applications were electronically submitted or caused to be submitted by

the borrower and received by the SBA. Once approved, the business received the PPP loan

proceeds via an electronic funds transfer from the third-party lender to a financial account under

the control of the business.

29. The proceeds of a PPP loan could be used for certain specified items, such as payroll

costs or mortgage interest payments. The proceeds of a PPP loan were not permitted to be used by

6
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 7 of 15

the borrowers to purchase consumer goods, automobiles, personal residences, clothing, or jewelry,

to pay the borrower’s personal federal income taxes, or to fund the borrower’s ordinary day-to-

day living expenses unrelated to the specified authorized expenses.

30. Bank A was a third-party participating lender in the PPP and a federally insured

financial institution as defined in 18 U.S.C. § 20.

The Conspiracy

31. From about 2014 to at least 2023, CC-1 and KATZ agreed that KATZ would pay

CC-1 off the books for CC-1’s work at Gebsco and CDK and thereby not accurately report CC-

1’s full compensation on federal tax forms.

Objects and Purposes of the Conspiracy

32. The object of the conspiracy was to defraud the United States by impeding,

impairing, obstructing and defeating the lawful functions of the IRS in the ascertainment,

computation, assessment, and collection of revenue, that was: (1) income taxes, by filing false

corporate income tax returns, which did not accurately report compensation paid to CC-1; (2)

federal payroll taxes, by filing false and fraudulent Employer’s Quarterly Federal Tax Returns,

which underreported the true number of employees and the true and correct wages paid to CC-1

and failed to pay over the appropriate taxes; and (3) income taxes, by issuing false Forms W-2

that CC-1 used to prepare fraudulent Form 1040s, all in violation of Title 26, United States Code,

Sections 7201, 7202, and 7206.

33. The principal purpose of the conspiracy was to compensate CC-1 tax free and

thereby enrich CC-1, while lessening CDK’s and Gebsco’s tax obligations.

Manner and Means of the Conspiracy

34. Among the manner and means by which KATZ and CC-1 carried out the conspiracy

7
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 8 of 15

were the following:

a. Buying a home for CC-1’s ex-wife to live in rent-free;

b. Paying home expenses for CC-1’s ex-wife;

c. Paying college-related expenses for CC-1’s children;

d. Paying CC-1’s ex-wife and daughter in lieu of paying CC-1;

e. Paying personal expenses incurred by CC-1 and his ex-wife on Gebsco’s

and CDK’s corporate credit cards;

f. Paying for CC-1’s personal driver; and

g. Filing false tax forms for CDK and for Gebsco that did not accurately report

CC-1’s compensation.

Overt Acts in Furtherance of the Conspiracy

35. From in or about 2014 through in or about 2023, KATZ and CC-1 committed and

caused to be committed the following overt acts, among others, in furtherance of the conspiracy:

a. On or about January 22, 2015, Gebsco paid CC-1’s ex-wife $3,450;

b. On or about June 12, 2015, CDK paid CC-1’s daughter $595;

c. On or about November 17, 2015, Gebsco bought a house in Sudbury for

$585,000 for CC-1’s ex-wife to live in rent-free;

d. On or about April 15, 2016, CC-1 filed a Form 1040 for the tax year 2015

that did not accurately report the income he received.

e. On or about December 23, 2016, Gebsco paid CC-1’s daughter $2,975, in

increments of $595, out of five accounts, to conceal payments made on

behalf of CC-1 and to avoid detection by the IRS on a Form 1099 required

for payments over $600;

8
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 9 of 15

f. On or about February 26, 2016, KATZ executed and filed a Form 1096,

Annual Summary and Transmittal of United States Information Returns, for

Gebsco for 2015 that falsely did not include CC-1’s true earnings;

g. On or about April 21, 2016, Gebsco paid CC-1’s ex-wife $2,950;

h. On or about March 6, 2017, Gebsco paid CC-1’s ex-wife $1,000;

i. On or about January 3, 2018, KATZ paid CC-1’s daughter $2,975 in

increments of $595, out of five accounts, to conceal payments made on

behalf of CC-1 and to avoid detection by the IRS on a Form 1099 required

for payments over $600;

j. On or about January 17, 2018, KATZ filed a Form 941 for Gebsco for the

fourth quarter of 2017 that falsely did not report accurately the number of

employees, compensation to CC-1, and Gebsco’s employment tax liability;

k. On or about February 7, 2019, KATZ and CC-1 agreed to sell the house in

Sudbury, with profits to be for the benefit of CC-1’s ex-wife, with Gebsco

increasing her profit margin by $2,500 per month for every month that CC-

1 worked at Gebsco after January 1, 2018;

l. On or about April 16, 2019, KATZ filed a Form 941 for Gebsco for the first

quarter of 2019 that falsely did not report accurately the number of

employees, compensation to CC-1, and Gebsco’s employment tax liability;

m. On or about September 16, 2019, Gebsco paid CC-1’s ex-wife $1,200;

n. On or about July 7, 2020, Gebsco paid CC-1’s ex-wife $1,000;

o. On or about October 13, 2020, KATZ filed a Form 941 for Gebsco for the

third quarter of 2020 that falsely did not report accurately the number of

9
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 10 of 15

employees, compensation to CC-1, and underreported Gebsco’s

employment tax liability;

p. On or about January 13, 2021, CC-1 paid $2,713.80 from Gebsco to a

Connecticut university for tuition for CC-1’s son;

q. On or about April 20, 2021, KATZ filed a Form 941 for Gebsco for the first

quarter of 2021 that did not report accurately the number of employees,

compensation to CC-1, and Gebsco’s employment tax liability;

r. On or about February 15, 2022, CC-1 paid $5,088 from Gebsco to a

Connecticut university for tuition for CC-1’s son;

s. On or about April 14, 2022, KATZ filed a Form 941 for Gebsco for the first

quarter of 2022 that falsely did not report accurately the number of

employees, compensation to CC-1, and Gebsco’s employment tax liability;

t. On or about July 15, 2023, CC-1 paid $3,309 from Gebsco to a Connecticut

university for tuition for his son; and

u. On or about October 12, 2023, KATZ filed a Form 941 for Gebsco for the

third quarter of 2023 that falsely did not report the accurate compensation

to CC-1 and underreported Gebsco’s employment tax liability.

The PPP Fraud

36. On or about April 2, 2020, KATZ filled out, signed, and submitted a PPP loan

application to Bank A to obtain a PPP loan to Gebsco in the amount $142,500.

37. As part of the Gebsco PPP application, KATZ falsely certified that as the applicant,

he was not engaged in any activity that was illegal under federal law, when, in fact, he was then

10
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 11 of 15

helping CC-1 to evade income taxes and evading employment taxes on the under-the-table

compensation he was paying to CC-1.

38. In support of the Gebsco PPP application, KATZ provided false payroll documents

to Bank A, including false Forms 941 for tax year 2019 that did not include off-the-books

compensation paid to CC-1.

39. On or about April 3, 2020, KATZ filled out, signed, and submitted a PPP loan

application to Bank A to obtain a PPP loan to CDK in the amount $37,400.

40. As part of the CDK PPP application, KATZ falsely certified that as the applicant,

he was not engaged in any activity that was illegal under federal law, when, in fact, he was then

helping CC-1 to evade income taxes and evading employment taxes on the under-the-table

compensation he was paying to CC-1.

41. In support of the CDK PPP application, KATZ provided Bank A false payroll

documents, including false Forms 941 for tax year 2019 that did not include an accurate statement

of compensation paid to CC-1.

42. In 2020, KATZ paid CC-1 at least $174,608.33 in off-the-books compensation,

causing the IRS a tax loss of at least $77,799.

43. On or about June 16, 2021, CC-1, acting as Gebsco’s Chief Operating Officer, filled

out, signed, and submitted a PPP loan forgiveness application for the $142,500 PPP loan to

Gebsco.

44. On or about June 28, 2021, the SBA forgave the $142,500 PPP loan to Gebsco.

45. On or about July 9, 2021, KATZ filled out, signed, and submitted a PPP loan

forgiveness application for the $37,400 PPP loan to CDK.

46. On or about July 16, 2021, the SBA forgave the $37,400 PPP loan to CDK.

11
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 12 of 15

COUNT ONE
Conspiracy to Defraud the United States
(18 U.S.C. § 371)

The United States Attorney charges:

47. The United States Attorney re-alleges and incorporates by reference paragraphs 1

through 46 of this Information.

48. From in or about 2014 through in or about 2023, in Sudbury, in the District of

Massachusetts, the defendant,

CHARLES D. KATZ,

conspired with others known to the U.S. Attorney to defraud the United States, that is, to impede,

impair, obstruct, and defeat the lawful function of the Internal Revenue Service in the

ascertainment, computation, assessment, and collection of income taxes and employment taxes.

All in violation of Title 18, United States Code, Section 371.

12
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 13 of 15

COUNTS TWO AND THREE
False Loan Application
(18 U.S.C. § 1014)

The U.S. Attorney charges:

49. The U.S. Attorney re-alleges and incorporates by reference paragraphs 1 through

46 of this Information.

50. On or about the dates listed below, in Sudbury, in the District of Massachusetts, the

defendant,

CHARLES D. KATZ,

knowingly made a false statement and report for the purpose of influencing in any way the action

of Bank A, an institution the accounts of which were insured by the Federal Deposit Insurance

Corporation, and of the United States Small Business Administration, upon any application or

loan, to wit, applications for Paycheck Protection Program loans:

Count Approximate Date Description
2 April 2, 2020 PPP Application for Gebsco
3 April 20, 2020 PPP Application for CDK

All in violation of Title 18, United States Code, Section 1014.

13
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 14 of 15

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

51. Upon conviction of one or more of the offenses in violation of Title 18, United

States Code, Section 1014, set forth in Counts 2 and 3, the defendant,

CHARLES D. KATZ,

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:

a. $179,500, to be entered in the form of a forfeiture money judgment;

52. If any of the property described in Paragraph 53, 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 --

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;

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 53 above.

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

States Code, Section 2461(c).

14
Case 1:25-cr-10407-LTS Document 1 Filed 10/20/25 Page 15 of 15

Respectfully submitted,

LEAH B. FOLEY
United States Attorney

By: /s/Kriss Basil
KRISS BASIL
Assistant United States Attorney

File and source

File: 1-information.pdf
Size: 160,380 bytes
SHA-256: 2c6900d342a92bf19dc543a97d8cd219fe461521cf0b2a786f4f338ea42fac2b
Our copy: 1-information.pdf
Original: archive.org