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.

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