UNITED STATES V. 15712 GULF BLVD.: 

VERIFIED COMPLAINT FOR FORFEITURE PAGE 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

TYLER DIVISION 

UNITED STATES OF AMERICA, § 

Plaintiff, §

 § 

v. § No. 6:23-CV-296

 §

REAL PROPERTY LOCATED AT § 

15712 GULF BOULEVARD § 

REDINGTON BEACH, § 

PINELLAS COUNTY, § 

FLORIDA, INCLUDING ALL § 

BUILDINGS, APPURTENANCES, § 

AND IMPROVEMENTS THEREON § 

Defendant. §

VERIFIED COMPLAINT FOR FORFEITURE 

In accordance with Fed. R. Civ. P. Supplemental Rule G(2), the United 

States of America, Plaintiff, brings this complaint for forfeiture and alleges as 

follows: 

NATURE OF ACTION 

1. This matter is an in rem action brought against the following

Defendant Real Property located at 15712 Gulf Boulevard, Redington Beach, 

Pinellas County, Florida: 

Portion of Lot (s) 5 and 6, Block 10, First Addition to Lone Palm 

Beach, according to the map or plat thereof, as recorded In Plat 

Book 20, Page(s) 67, of the Public Records of Pinellas County, 

Florida, described as follows: Commence at the most Northerly 

Corner of said Lot 5; thence along the Northwesterly Boundary 

line of said Lot 5, South 36°59’00” West, 7.00 feet to the existing 

Southwesterly Right-of-way line of Gulf Boulevard, thence along 

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said Right-of-way line, South 53"01 '00" East, 45.00 feet for a 

Point of Beginning; thence from said Point of Beginning the 

following four (4) Courses: 1) Continue along said Right-of-Way 

line, South 53"0TO0" East, 45.00 feet; thence 2) Leaving said 

Right-of-Way line, South 36° 59W West, 173.87 feet; thence 3) 

North 53“22’03” West, 45.00 feet; thence 4) North 36°59'00” East, 

174.14 feet, to the aforementioned Point of Beginning. a/k/a 

15712 Gulf Blvd. Redington Beach Florida. 

JURISDICTION AND VENUE 

2. The Court has subject matter jurisdiction over an action 

commenced by the United States pursuant to 28 U.S.C. § 1345 and over an 

action for forfeiture pursuant to 28 U.S.C. § 1355(a). 

3. The Court has in rem jurisdiction over the defendant property 

pursuant to 28 U.S.C. § 1355(b)(1)(A) because acts or omissions giving rise to 

the forfeiture occurred in the Eastern District of Texas. 

4. Venue is proper pursuant to 28 U.S.C. § 1355(b)(1)(A) because 

acts or omissions giving rise to the forfeiture occurred in the Eastern District 

of Texas. 

FACTUAL BACKGROUND 

Background on IRS Forms and Frivolous Arguments 

5. Each year, taxpayers have the option of either mailing their 

federal income tax return to the IRS or filing their tax return electronically 

(e-file). A taxpayer can prepare and file their electronic tax return themselves 

using available software or hire a return preparer to prepare and 

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electronically file the tax return. The software company provides technical 

support to the return preparer and monitors the returns that are filed 

through its software system. 

6. Form 1041, U.S. Income Tax Return for Estates and Trusts 

(Form 1041), is an income tax return required to be filed by certain estate 

and trust entities. When a Form 1041 is e-filed with the IRS, Form 8453-FE, 

U.S. Estate or Trust Declaration for an IRS e-file Return (Form 8453-FE), is 

required to be electronically filed as an attachment to the Form 1041. 

7. Original Issue Discount (OID) is a type of interest that is not 

payable as it accrues. OID is the excess of the stated redemption of the 

deposit, bond, or other financial obligation at maturity over its issue price. 

OID is taxable as interest over the life of the obligation and must be included 

in the holder’s gross income each taxable year that the obligation is held. 

Certain obligations are excepted, including United States savings bonds, 

short-term obligations (less than one year), and tax-exempt obligations. 

8. Investment income, including OID, is generally not subject to 

federal income tax (FIT) withholding. However, OID may be subject to 

backup withholding of 28% for tax year 2017 (or 24% for tax years 2018 

through 2023) of the amount the taxpayer received for OID. Backup 

withholding may apply if: (1) the payee fails to furnish his or her tax 

identification number (TIN); (2) the payee fails to certify to the payer, under 

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penalties of perjury, that the TIN provided is correct; (3) the IRS notifies the 

payer to impose backup withholding because the payee furnished an incorrect 

TIN; (4) the IRS notifies the payer that the payee is subject to backup 

withholding; or (5) the payee fails to certify to the payer, under penalties of 

perjury, that he or she is not subject to backup withholding. 

9. Form 1099-OID, Original Issue Discount (Form 1099-OID), is a 

Form 1099 series information return to report the OID of holders of OID 

obligations, including certificates of deposit, time deposits, bonds, debentures, 

bonus savings plans, and Treasury inflation-indexed securities, having a 

term of more than one year. Form 1099-OID is generally required to be filed 

with the IRS by certain financial institutions when the total OID for a holder 

or depositor is at least $10.00, or when any amount of Federal Income Tax 

(FIT) is withheld and not refunded to the holder or depositor, in a calendar 

year. 

10. On March 22, 2004, the IRS published Internal Revenue Bulletin: 

2004-12. Internal Revenue Bulletin: 2004-12 included a discussion of 

Revenue Ruling 2004-31 on frivolous tax returns and meritless “removal 

arguments.” Revenue Ruling 2004-31 emphasizes to taxpayers that there is 

no law, court decision, or other authority that permits a taxpayer to remove 

themselves from the federal tax system to avoid otherwise applicable taxes. 

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11. According to Revenue Ruling 2004-31, removal arguments and 

schemes are loosely related and take a variety of different forms. In some 

variations of the removal argument, individuals claim that the government 

commits a fraud when it attempts to collect debts, including tax debts, and 

that this purported fraud allows individuals to “chargeback” debts that the 

government purportedly owes to these individuals to eliminate any liability 

to the government. Other individuals argue that they may reclaim, or 

“chargeback,” their own value from the government as a result of the 

government’s purported wrongful conduct and then use that value to pay the 

individual’s debts. Participants in removal schemes often attempt to offset, 

collect, or “redeem” their asserted claims against the government by using or 

filing false liens, bills of exchange, and various Uniform Commercial Code 

(UCC) forms, or by relying on misinterpretations of federal laws and the 

UCC. Arguments that individuals may be removed or redeemed from the 

federal tax system, or may “chargeback” their debts to the government, have 

no merit and are frivolous. 

12. On April 4, 2005, the IRS published Internal Revenue Bulletin: 

2005-14. Internal Revenue Bulletin: 2005-14 included a discussion of 

Revenue Ruling 2005-21 on frivolous tax returns and use of the “straw man” 

theory to avoid tax. Revenue Ruling 2005-21 emphasizes to taxpayers that 

they cannot avoid income tax on the theory that the government has created 

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a separate and distinct entity, or “straw man,” in place of the taxpayer and 

that the taxpayer is not responsible for the tax obligations of the “straw 

man.” 

13. According to Revenue Ruling 2005-21, the “straw man” claim is 

premised on the erroneous theory that most government documents do not 

actually refer to individuals. Users of the “straw man” theory falsely claim 

that only documents using an individual’s name with “standard” 

capitalization, i.e., lower-case with only the beginning letters of each name 

capitalized, are legitimate. These individuals argue that the use of the 

individual’s name in all upper-case letters, which is common in some 

government documents, refers to a separate legal entity, called a “straw 

man.” These individuals also argue that, as a result of the creation of the 

“straw man,” they are not liable for the debts, including the tax debts, of their 

“straw man,” that taxing the “straw man” is illegal or unconstitutional 

because the “straw man” is a debt instrument based upon the labor of a real 

person and is, therefore, a form of slavery, or that no tax is owed by the real 

individual because it can be satisfied, or offset, by money in a “Treasury 

Direct Account” held in the name of the “straw man.” In reality, the use of 

different forms of a taxpayer’s name, including different spellings or 

capitalization, does not create a “straw man” that allows taxpayers to avoid 

their federal tax obligations. Claims based on “straw man” arguments, or on 

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similar arguments, to avoid federal tax obligations are frivolous and have no 

merit. 

14. In an OID scheme, filers falsely list large amounts of OID income 

and corresponding large amounts of withholding. Instead of listing actual 

OID income, the filers list a debt, including credit card debts and mortgages. 

The filers also falsely represent that a large amount of their OID income was 

withheld, and they thus claim that they are entitled to large tax refunds. One 

variation of the “redemption theory” (removal argument) asserts that persons 

can draw on a secret or “straw man” Treasury account by sending a Form 

1099-OID to a creditor and the creditor can present the form to the Treasury 

Department and receive a full payment of the debt. The proponents of this 

theory appear to assert that the Form 1099-OID permits them to access their 

secret Treasury account for an amount equal to the face amount of the Form 

1099-OID in the form of a tax refund. Persons asserting this theory often 

significantly overstate withholding and claim an excessive refund in an 

amount close or identical to the related withholding. Form 1099-OID is in no 

way a financial instrument. Form 1099-OID is not a legitimate method of 

payment of any public or private debt, and Form 1099-OID is not a means to 

withdraw or “redeem” money from the Treasury Department or IRS. 

15. Further variations of this frivolous Form 1099-OID theory 

contend that individuals may claim false withholding or tax payments on an 

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income tax return or purported return using another document from the 

Form 1099 series of information returns, including Forms 1099-C, 

Cancellation of Debt (Forms 1099-C), and Forms 1099-A, Acquisition or 

Abandonment of Secured Property (Forms 1099-A). 

The Purchase of 15712 Gulf Boulevard, Redington Beach, Florida 

16. Larry Mark Kalmowitz and Rebecca Ann Kalmowitz purchased 

15712 Gulf Boulevard in Redington Beach, Florida on or about January 29, 

2020. The warranty deed filed with the Pinellas County Clerk on or about 

February 3, 2020, identified CORPORATE HOLDINGS COMPANY, LLC 

(CHC) as the purchaser. A Florida Limited Liability Company Affidavit was 

also filed with the Pinellas County Clerk on or about February 3, 2020, which 

identified the Kalmowitzes as the authorized persons for CHC. 

17. A warranty deed filed with Pinellas County Clerk on or about 

November 30, 2022, identified CHC as grantor to the Kalmowitzes for 15712 

Gulf Boulevard in Redington Beach, Florida effective December 31, 2020. 

Proceeds from Underlying Specified Unlawful Activities Are Used to 

Purchase 15712 Gulf Boulevard 

18. In May 2017, Larry Kalmowitz filed a Form SS-4, Application for 

Employer Identification Number, with the IRS for LARRY MARK 

KALMOWITZ ESTATE (LMK ESTATE). In January 2018, he filed a Form 

SS-4 with the IRS for LARRY MARK KALMOWITZ TRUST (LMK TRUST). 

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19. Also in May 2017, Rebecca Kalmowitz filed a Form SS-4 with the 

IRS for REBECCA ANN KALMOWITZ ESTATE (RAK ESTATE). In January 

2019, she filed a Form SS-4 with the IRS for REBECCA ANN KALMOWITZ 

TRUST (RAK TRUST). 

20. Between June 3, 2019, and February 6, 2020, the IRS received 10 

e-filed, false Forms 1041 for LMK ESTATE, LMK TRUST, RAK ESTATE, 

and RAK TRUST for tax years including 2017, 2018, and 2019. 

21. The false Forms 1041 reported a total of approximately $48 

million in fictitious interest income and approximately $48 million in 

fictitious FIT withheld from Forms 1099. On eight of the false Forms 1041, 

the fictitious interest income and FIT withheld are the same amount, or 

100% of income was reported as withheld as FIT. 

22. The false Forms 1041 calculated approximately $6 million in 

total tax, and total refunds of approximately $42 million. Due to a flaw in the 

processing system that did not recognize the fraudulent nature of the claims, 

the IRS issued Treasury Checks for the refunds claimed on eight of the 

Forms 1041 for a total of approximately $24 million. The last two refunds 

were stopped by the IRS before Treasury Checks were issued, for a total of 

approximately $18 million. 

23. There were no Forms 1099 filed with the IRS by any payer for 

income paid to or federal income tax withheld for LMK ESTATE, RAK 

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ESTATE, or RAK TRUST for tax years 2017, 2018, or 2019. There were 

Forms 1099-INT, Interest Income (Forms 1099-INT), for LMK TRUST for tax 

years 2019 and 2020. The Forms 1099-INT for LMK TRUST reported total 

interest income of $19.00 and total FIT withheld of $4.00 in 2019, and total 

interest income of $25.00 and total FIT withheld of $6.00 in 2020. There were 

no other Forms 1099 filed with the IRS for LMK TRUST for tax years 2017, 

2018, or 2019. 

24. Records from Tax Software Provider 1 show that an account 

registered to Larry Kalmowitz prepared 87 Forms 1099-A for a total of 

approximately $35.7 million in purported principal balances for tax years 

2016 to 2019. 

25. Records from Tax Software Provider 1 show that an account 

registered to Rebecca Kalmowitz prepared 86 Forms 1099-A for a total of 

approximately $28 million in purported principal balances for tax years 2016 

to 2019. 

26. Records from Tax Software Provider 2 show that an account 

registered to Rebecca Kalmowitz prepared and electronically filed the 10 false 

Forms 1041 for LMK ESTATE, LMK TRUST, RAK ESTATE, and RAK 

TRUST for tax years 2017, 2018, and 2019. The Forms 1041 were prepared 

with Forms 1099-OID entered as supporting the interest income and FIT 

withheld claimed on the Forms 1041. 

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27. The IRS received Certified Mail packages containing printed 

copies of 2017 Forms 1041 for LMK TRUST, LMK ESTATE, and RAK 

ESTATE postmarked November 12, 2019, November 27, 2019, and December 

2, 2019, respectively. Each package included Forms 1096, Annual Summary 

and Transmittal of U.S. Information Returns, and Forms 1099-OID listing 

LMK TRUST, LMK ESTATE, and RAK ESTATE as the payer, respectively. 

The Forms 1096 included the Kalmowitzes’ signatures, respectively. The 

Forms 1099-OID included handwritten alterations to the tax year and the 

checkbox as “Corrected” forms for tax year 2017. Each of the Certified Mail 

packages also included fictitious bonds and other documents that appear to 

promote frivolous argument theories. 

28. On July 2, 2019, the Kalmowitzes opened a J.P. Morgan Chase 

checking account number XXXXX6302 (JPMC #6302), titled to LMK TRUST. 

The signature cards show both Kalmowitzes as authorized signers for JPMC 

#6302 dated July 2 and July 11, 2019. The same day he opened JPMC #6302, 

Larry Kalmowitz deposited the Treasury Check for the 2018 Form 1041 

refund for LMK TRUST in the amount of $329,022.00 into that account. On 

December 21, 2019, Larry Kalmowitz deposited the Treasury Check for the 

2017 Form 1041 refund for LMK TRUST in the amount of $2,416,079.00 into 

that same account. 

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29. On November 18, 2019, the Kalmowitzes opened a checking 

account with Bank of America in the name of LMK ESTATE (BofA #9355). 

The signature card shows both Kalmowitzes as authorized signers for BofA 

#9355 dated November 27, 2019. Larry Kalmowitz deposited the Treasury 

Check for the 2018 Form 1041 refund for LMK ESTATE in the amount of 

$763,413.00 into the BofA #9355 account on November 20, 2019. He 

deposited the Treasury Check for the 2017 Form 1041 refund for LMK 

ESTATE in the amount of $5,662,720.00 into the BofA #9355 account on 

December 20, 2019. 

30. On November 19, 2019, the Kalmowitzes opened a checking 

account with BofA in the name of RAK ESTATE (BofA #6499). The signature 

card dated November 27, 2019 shows both Kalmowitzes as authorized signers 

for BofA #6499. On November 20, 2019, Rebecca Kalmowitz deposited the 

Treasury Check for the 2018 Form 1041 refund for RAK ESTATE in the 

amount of $800,002.00 into BofA #6499. 

31. On December 2, 2019, Rebecca Kalmowitz opened a BofA 

checking account (BofA #5338) in the name of HELPING HANDS MINISTRY 

SSM (HHM). The accounting opening document lists Rebecca Kalmowitz as 

“Exec. Director” and Larry Kalmowitz as “Managing Director” and both 

Kalmowitzes as authorized persons for the BofA #5338. Over the next few 

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weeks, the Kalmowitzes made substantial deposits into BofA #5338 from 

their other BofA accounts and their JPMC account: 

Date Origin of Deposit Amount 

12/31/19 BofA #9355, Check #1002 $50,000.00 

12/31/19 BofA #6499, Check #1003 $75,000.00 

1/15/20 JPMC #6302, Check #181 $500,000.00 

1/16/20 BofA #9355, Check #1008 $4,400,000.00 

TOTAL $5,025,000.00 

32. On January 8, 2020, Larry Kalmowitz signed the withdrawal slip 

to purchase a cashier’s check to Title Agency of Florida for $100,000.00 from 

BofA #5338 dated January 8, 2020. The memo line of the cashier’s check read 

“15712 GULF BLVD-REDINGTON BEACH.” 

33. On January 29, 2020, a wire transfer was sent to Gulf Water 

Title for approximately $4.4 million from BofA #5338. The originator to 

beneficiary instructions stated “PURCHASER HELPING HANDS 

MINISTRY SSM PROP ADDRESS 15712 GULF BLVD REDINGTON 

BEACH FL 33708.” 

34. That same day, the Kalmowitzes signed the closing documents 

and provided their U.S. Passport Cards as identification to purchase 15712 

Gulf Boulevard, Redington Beach, Florida 33708 for approximately $4.5 

million. The closing documents were titled to CHC. The Kalmowitzes signed a 

Florida Limited Liability Company Affidavit as authorized signors of CHC as 

part of the closing package. 

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35. Based on a review of these records, the records show that the 

$4,511,455.05 paid for 15712 Gulf Boulevard, Redington Beach, Florida came 

from the Treasury Check funds that were deposited in JPMC #6302, BOA 

#6499, and #9355 and subsequently transferred to BOA #5338. 

BASIS FOR FORFEITURE 

36. The Defendant Real Property, 15712 Gulf Boulevard, Redington 

Beach, Pinellas County, Florida is subject to forfeiture pursuant to 18 U.S.C. 

§§ 981(a)(1)(A) and 981(a)(1)(C) because it constitutes property involved in 

transactions or attempted transactions in violation of 18 U.S.C. § 1957 and/or 

is property traceable to violations of 18 U.S.C. §§ 1341 and 1343. 

37. The Kalmowitzes e-filed ten separate Form 1041s that all 

contained fraudulent information causing the Treasury to issue eight checks 

by USPS to a USPS P.O. box in Tyler, Texas. All ten fraudulent Forms 1041 

contained the same P.O. box as the return address, which caused the mailing 

of proceeds of the fraud scheme to be mailed by USPS to the P.O. box. Of the 

ten fraudulent e-filed Form 1041s, the investigation has confirmed at least 

three of those were followed up by the Kalmowitzes by mailing via USPS 

hard copies of those forms and the supporting fraudulent 1099-OIDs that 

contained material misrepresentations. There is a pending IRS archives 

check attempting to locate the hard copy records related to the other seven 

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Form 1041s. The Kalmowitzes obtained the aforementioned illegal proceeds 

by way of mail fraud in violation of 18 U.S.C. § 1341. 

38. The internet protocol (IP) addresses used to submit all ten of the 

fraudulent Forms 1041 were also used by subjects of a related investigation. 

The Kalmowitzes both used the same IP addresses to file returns. The first 

three returns were filed from IP 74.192.114.158 which is known to be 

serviced by Suddenlink Communications and registered to Larry Kalmowitz 

at 730 Hampton Hill Road, Tyler, Texas 75701, the Kalmowitzes’ former 

residence prior to foreclosure by Wells Fargo for non-payment. The next five 

returns were filed from IP 208.180.168.11 also serviced by Suddenlink 

Communications and registered to Staybridge Suites, 2759 McDonald Road, 

Tyler, Texas 75701. The final two returns, which were stopped from refunds 

being issued, were filed from a Charter Communications IP address. IP 

35.136.166.14 is held by Charter Communications and is registered to Larry 

Kalmowitz. All 10 returns were also filed using TaxAct Inc.'s preparation 

software. The Kalmowitzes obtained the aforementioned illegal proceeds by 

way of wire fraud in violation of 18 U.S.C. § 1343. 

39. Because the Defendant Real Property constitutes property 

purchased from monetary transactions by and through a financial institution 

affecting interstate commerce in criminally derived property having a value 

greater than $10,000, such property having been derived from specified 

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unlawful activities—that is, mail fraud and wire fraud in violation of 18 

U.S.C. §§ 1341 and 1343, respectively—it is forfeitable due to violations of 18 

U.S.C. § 1957. 

40. The Defendant Real Property has not been seized. 

41. The government does not request authority from the Court to 

seize the above-listed real property at this time. Pursuant to 18 U.S.C. § 

985(b)(1) and 985(c)(1), the government will instead do the following: 

a. Post notice of this action and a copy of the Complaint on 

the property; 

b. Serve notice of this action and a copy of this Complaint on 

the real property owner and any other person or entity who 

may claim interest in the real property; and 

c. File a lis pendens in county records of the real property’s 

status as a defendant in this in rem action. 

POTENTIAL CLAIMANTS 

42. The potential claimants to the defendant property are: 

Larry Mark Kalmowitz 

15712 Gulf Boulevard 

Redington Beach, Florida 33708 

Rebecca Ann Kalmowitz 

15712 Gulf Boulevard 

Redington Beach, Florida 33708 

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Ken Burke, CPA 

Clerk of the Circuit Court and Comptroller, Pinellas County, FL 

315 Court Street 

Clearwater, Florida 33756 

CLAIM FOR RELIEF 

43. The United States respectfully requests that the Court forfeit the 

Defendant Real Property to the United States, award costs and 

disbursements in this action to the United States, and order any other relief 

that the Court deems appropriate. 

 Respectfully submitted, 

 DAMIEN M. DIGGS 

 UNITED STATES ATTORNEY 

/s/ Robert Austin Wells 

 ROBERT AUSTIN WELLS 

 Assistant United States Attorney 

 Texas State Bar No. 24033327 

 110 N. College, Suite 700 

 Tyler, Texas 75702 

 Tel: (903) 590-1400 

 Fax: (903) 590-1439 

robert.wells3@usdoj.gov 

 ATTORNEYS FOR THE UNITED

 STATES 

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