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FILED 1 SEP '1515:20.JSDC-t:RP 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA 

v. INFORMATION 

TIAIRRE TRA VONNE CHANEY, 18 u.s.c. § 1341 

Defendant. 

THE UNITED ST ATES ATTORNEY ALLEGES: 

GENERAL ALLEGATIONS 

At all times relevant to this Information: 

1. Defendant TIAIRRE TRA VONNE CHANEY ("CHANEY") resided in 

Portland, Oregon. 

2. CHANEY prepared tax returns in her own name and the names of third parties 

and electronically filed them with the Internal Revenue Service (IRS) via the Internet, from her 

homes on Southeast Stark Street and Southeast 162nd A venue in Portland. 

3. The IRS is an agency of the United States Department of the Treasury and is 

responsible for enforcing and administering the tax laws of the United States, collecting taxes 

owed to the United States, and issuing refunds for excessive tax payments. 

4. The IRS Form 1040A Individual Income Tax Return is a preprinted form used by 

individual taxpayers to report income, tax withholdings or payments, and any tax due to or 

refunds due from the IRS. Form 1040A may be filed with: Schedule EiC, on which taxpayers 

substantiate their eligibility for refundable tax credits for dependents in their care by identifying 
,. 

those dependents and describing their status; Schedule M, on which taxpayers claim eligibility 

for the "Making Work Pay" refundable tax credit; and Form 8812, on which taxpayers claim 

eligibility for the "Additional Child Tax Credit." When a taxpayer's total tax liability for the 

year, based on his or her income minus deductible expenses (if any), is less than the sum of the 

taxpayer's refundable tax credits and taxes previously withheld or otherwise paid for that year, 

the taxpayer is entitled to a refund, that is, a payment from the IRS. 

5. During the times relevant to this Information, the IRS routinely issued refunds to 

taxpayers before verifying the accuracy of the income, expenses, dependents, withholdings and 

credits claimed on their tax returns or the actual identities of persons filing the returns. 

COUNTl 

(Wire Fraud) 

(18 u.s.c. § 1343) 

I. The General Allegations in paragraphs I through 5 of this Information are realleged and incorporated herein. 

2. Beginning not later than January 2011 and continuing through April 2011, 

defendant CHANEY devised and intended to devise a material scheme to defraud the IRS and 

other victims, and to obtain money and property by means of materially false and fraudulent 

pretenses, representations and promises. 

SCHEME TO DEFRAUD 

3. By January 6, 2011, defendant CHANEY discovered that she could cause the IRS 

to issue an unwarranted tax refund to a purported taxpayer by filing a false IRS Form I 040A 

claiming fictitious dependents and overstating the purported taxpayer's eligibility for refundable 

tax credits. 

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4. Defendant CHANEY fraudulently increased unwarranted refunds by inflating the 

number of dependents claimed by purported taxpayers, recording the names, birthdates, and 

Social Security numbers of actual persons unrelated to such taxpayers on their IRS Forms 

1040A, Schedules EiC, and Forms 8812. 

5. Defendant CHANEY fraudulently overstated or misrepresented purported 

taxpayers' earned income by recording fictitious wages, in amounts between $8,900 and 

$12,700, on line 7 of the taxpayers' IRS Forms 1040A. Such levels of earned income 

maximized the purported taxpayers' eligibility for refundable tax credits. 

6. Defendant CHANEY directed the IRS to pay unwarranted refunds generated in 

this manner by mailing U.S. Treasury checks or pre-paid "stored value" credit cards to addresses 

that CHANEY directly controlled or to which she otherwise had access. CHANEY would give 

only a part of the fraudulently claimed refunds to the purported taxpayers named on the false 

returns. 

7. From January 6, 2011, through approximately May 3, 2011, defendant CHANEY 

electronically filed thirty-five fraudulent returns with the IRS, claiming for herself and others 

unwarranted tax refunds totaling $155,670. 

Ill 

Ill 

Ill 

Ill 

Ill 

Ill 

Ill 

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8. On or about February 22, 2011, in the District of Oregon, defendant TIAIRRE 

TRA VONNE CHANEY, for the purposes of executing the scheme described above, caused to 

be transmitted by means of wire communication in interstate commerce, to wit, from 

CHANEY's residence in Portland, Oregon, to the IRS Service Center in Fresno, California, an 

electronic IRS Form 1040A for the year 2010 in the name of "T_H_", claiming a fraudulent 

refund of $6,878. 

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

Dated this 1st day of September 2015. 

Respectfully submitted, 

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