150 Months in Prison for Tax Fraud
Post 4846
Posted on September 17, 2026 by Barry Zalma
See the full video at https://lnkd.in/g8rh3JBX and https://lnkd.in/gmkdy-9C, In United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.
FACTS
In United States Of America v. Thomas Addaquay, United States Of America v. Thomas Addaquay, Nos. 25-10609, 25-10611, United States Court of Appeals, Eleventh Circuit (September 9, 2026) the Eleventh Circuit affirmed all challenged convictions, the 150-month aggregate sentence, and the challenged $4,123,474.55 restitution award.
FACTS
Thomas Addaquay controlled United Consolidated Accounting and Business Services (UC), nominally a check-cashing business.
The government proved a three-stage tax-refund scheme that converted the resulting refund checks into usable funds through ReliaFund, which processed roughly $13 million in UC deposits.
A jury convicted him on 29 tax-refund-fraud counts, including wire fraud and aggravated identity theft. In a separate case he pleaded guilty to structuring transactions to evade reporting requirements; the cases were consolidated for sentencing.
After trial, the government disclosed one memorandum recounting Michael Awiti’s statements and three documents concerning Gianna Liady’s separate tax-fraud operation. Addaquay sought dismissal or a new trial broader discovery, and a lower loss calculation.
The district court denied the post-trial relief and imposed an aggregate sentence of 150 months.
LAW
Sufficiency: Evidence is viewed in the light most favorable to the government; a conviction stands if any reasonable construction supports guilt beyond a reasonable doubt.
Wire fraud: The government must prove a scheme to defraud, intent, and use or causation of interstate wires to execute the scheme.
Aggravated identity theft: During and in relation to a predicate felony, the defendant or someone he aided must knowingly use, without lawful authority, another person’s means of identification.
Brady: Suppressed favorable evidence warrants relief only if there is a reasonable probability that timely disclosure would have changed the outcome; multiple items are assessed cumulatively.
Giglio: Relief requires the knowing use or failure to correct materially false testimony; additional or impeaching detail alone is not perjury.
Loss and restitution: The government must prove loss by a preponderance. Restitution must reflect actual loss caused by the defendant, but may also rest on a reasonable estimate supported by the record.
DISCUSSION AND ANALYSIS
1. Sufficiency of the Evidence
The court held that ample direct and circumstantial evidence placed Addaquay throughout the enterprise.
The government did not need to prove that every UC check was fraudulent or that Addaquay personally filed every return or sent every wire.
The aggravated-identity-theft convictions likewise stood. Addaquay received personal information and directed forged taxpayer signatures allowed the jury to find advance knowledge and intentional assistance, satisfying Rosemond.
2. DISCOVERY
Assuming favorable evidence was suppressed, the Awiti memorandum was not material. Independent witnesses and records strongly corroborated Addaquay’s role. The memorandum also did not establish false testimony: silence, uncertainty, or added detail was not a contradiction sufficient for Giglio.
Considered cumulatively, the four documents did not create a reasonable probability of a different verdict.
3. MOTION TO COMPEL
The district court reasonably drew a line between materials directly testing loss and speculative requests. This was tailored discovery, not improper burden shifting.
4. LOSS AND RESTITUTION
The government sampled 300 checks from the relevant pool and used IRS Transaction Code 841 as a conservative indicator of attempted refund freezes or reversals. Addaquay’s expert identified an outlier and a sampling error and proposed a median-based estimate of $5,497,966.07. The district court accepted the defense-favorable median, then reduced it another 25% to account for potentially legitimate checks, Code 841’s imperfections, and fraud insufficiently attributable to Addaquay, producing $4,123,474.55.
CONCLUSION
The Eleventh Circuit affirmed. The district court’s methodology estimated actual loss to the IRS: refunds that the IRS paid and that UC processed through ReliaFund.
ZALMA OPINION
After a jury convicted Thomas Addaquay and the District Court sentenced him to serve 150 months and pay restitution $4,123,474.55 Addaquay asked the Eleventh Circuit to change the sentence. He failed because his claims were inadequate and his sentence stood and he will be in Federal Prison for 12.5 years without a chance of parole.
(c) 2026 Barry Zalma & ClaimSchool, Inc.
Please tell your friends and colleagues about this blog and the videos and let them subscribe to the blog and the videos.
Subscribe to my substack at https://gbarryzalma.substack.com/subscribe
Go to X @bzalma; Go to Barry Zalma videos at Rumble.com at https://rumble.com/account/content?type=all; Go to Barry Zalma on YouTube- https://www.youtube.com/channel/UCysiZklEtxZsSF9DfC0Expg; Go to the InsuranceClaims Library – https://lnkd.in/gwEYk.
Insurance Expert May Not Testify to Speculative and Contains Unsupported Conclusions.
Posted on September 18, 2026 by Barry Zalma
See the full video at and at https://rumble.com/v7fmifw-expert-may-only-testify-to-what-experience-supports.html
In Michele A. Over, and The Estate Of Paul R. Over v. State Farm Mutual Automobile Insurance Company, and State Farm Fire And Casualty Company, Civil Action No. 23-cv-02243-PAB-STV, United States District Court, D. Colorado (September 14, 2026) Michele and Paul Over sued State Farm Fire and State Farm Auto over hail-damage and stolen-vehicle claims.
The operative dispute concerned State Farm Auto’s motion to exclude or limit opinions from plaintiffs’ insurance-industry expert, Aaron Castillo. Castillo.
Law
The proponent of expert testimony must establish by a preponderance of the evidence that an expert is qualified and that the opinions are helpful, sufficiently grounded, and reliably derived and applied. Experience-based opinions must explain how the...
Major Fraud Perpetrator Asserts Fifth Amendment Privilege to Avoid Prosecution
Post 5489
Posted on September 14, 2026 by Barry Zalma
Fraudster Refuses to Answer Questions About His Alleged Fraud
See the full video at https://lnkd.in/gvicAMDr and at https://lnkd.in/gvicAMDr
In Great American Insurance Co. v. Gemstone Property Management, LLC, et al., No. 23-cv-9100 (LJL), United States District Court, S.D. New York (September 8, 2026) Great American Insurance Company alleged that it was defrauded through a scheme in which Subin Associates, LLP recruited individuals to stage construction-site injuries, arranged unnecessary medical treatment and litigation funding, and pursued fraudulent personal-injury claims.
Luis Manuel Garcia Salcedo, resulted in a $6 million settlement. Non-party Jose Hernandez allegedly worked as an assistant manager at Subin, operated Hernandez Associates, and owned litigation-funding companies that shared office space with Subin and provided services to its clients.
After Great American ...
Policy Limits Demand Accepted Settles Claim
Post 5434
Posted on August 26, 2026 by Barry Zalma
See the full video at https://lnkd.in/g-ZtsSgK and at https://lnkd.in/ghMBdYWR
A Contingent Offer Accepted Ends the Dispute
In Farmers Insurance Exchange, a California Reciprocal Insurance Exchange, The Superior Court For The County Of San Bernardino, Kathleen Ann Wood, E087128, California Court of Appeals, (July 9, 2026) Farmers Insurance Exchange insured Doyle Archer under an automobile policy with bodily injury limits of $15,000 per person and $30,000 per accident.
FACTUAL BACKGROUND
Archer rear-ended Kathleen Ann Wood at a red light, causing Wood to assert a bodily injury claim against him. Wood’s counsel sent Farmers a pre-litigation settlement demand offering to resolve Wood’s claim for the available policy limits, stating that if the $100,000 demand exceeded the policy, the offer was for the policy limits.
Farmers timely responded in writing, agreed to pay Wood the $15,000 per-person policy limit, and provided the requested ...
If Grounds For Dismissal Are Apparent From The Face Of The Complaint, A Court May Also Dismiss The Case on The Court’s Own Motion
Posted on October 5, 2026 by Barry Zalma
Pro Se Plaintiff Failed to Make a Short and Plain Statement
Post 4856
In Tak Lun Ng v. United Financial Casualty Company, No. 26-cv-03136-LJC, United States District Court, N.D. California (September 28, 2026) Tak Lun Ng, proceeding pro se, sued United Financial Casualty Company over a March 2, 2021 automobile accident and the insurer’s March 24, 2021 refusal to pay him.
He appeared to assert breach of contract, fraud, negligence, premises liability, product liability, and related theories. United removed the action from state court and moved to dismiss.
Ng missed that deadline but later filed several documents, including a motion for leave to amend, all of which the court reviewed.
LAW
Under Federal Rules of Civil Procedure, a complaint must provide a short and plain statement containing enough factual matter to state a facially plausible...
If Grounds For Dismissal Are Apparent From The Face Of The Complaint, A Court May Also Dismiss The Case on The Court’s Own Motion
Posted on October 5, 2026 by Barry Zalma
Pro Se Plaintiff Failed to Make a Short and Plain Statement
Post 4856
In Tak Lun Ng v. United Financial Casualty Company, No. 26-cv-03136-LJC, United States District Court, N.D. California (September 28, 2026) Tak Lun Ng, proceeding pro se, sued United Financial Casualty Company over a March 2, 2021 automobile accident and the insurer’s March 24, 2021 refusal to pay him.
He appeared to assert breach of contract, fraud, negligence, premises liability, product liability, and related theories. United removed the action from state court and moved to dismiss.
Ng missed that deadline but later filed several documents, including a motion for leave to amend, all of which the court reviewed.
LAW
Under Federal Rules of Civil Procedure, a complaint must provide a short and plain statement containing enough factual matter to state a facially plausible...
Employee Report of Fraud Results in Damages Suit After Qui Tam Suit Settled
No Statutory Hearing Right Arose Because No Dental Commission Complaint License Suspension, Revocation, Or Sanction Occurred.
Post 4855
Posted on October 2, 2026 by Barry Zalma
In Abbas Mohammadi et al. v. William M. Tong et al., No. AC 47598, Court of Appeals of Connecticut (September 29, 2026) Abbas Mohammadi owned and operated Columbia Dental, P.C., which provided dental services through multiple Connecticut offices; Columbia Oral Maxillofacial Imaging, LLC served as the billing entity.
From April 2012 to February 27, 2013, Columbia Dental employed Brittany Ames Mahoney as a dental assistant. During her employment, Mahoney claimed to have discovered certain billing irregularities, including, but not limited to, false and fraudulent reimbursement claims submitted to the Department of Social Services for services rendered to Medicaid beneficiaries. Mahoney filed a complaint and an affidavit in the United States District Court for the District of...
