Date: April 10, 2024 Contact: newsroom@ci.irs.gov A Florida attorney was sentenced today to eight years in prison for conspiring to defraud the United States and tax evasion arising out of his promotion of an illegal tax shelter scheme involving false charitable deductions. According to court documents and statements made in court, from at least 2013 through 2021, Michael L. Meyer, of Davie, FL, used his skills as an attorney and certified public accountant to promote his fraudulent tax shelter called “The Ultimate Tax Plan.” Meyer and his co-conspirators, Rao Garuda and Cullen Fischel, marketed the scheme as a way for high-income clients to reduce their taxes by claiming deductions for charitable donations that Meyer knew were fraudulent. Meyer prepared boilerplate transaction paperwork for his clients that made it appear they had donated valuable property to charities Meyer controlled. In fact, the clients retained complete control and use over the donated assets. Meyer wrongfully advised clients they could legally access their donated assets for their own personal use through tax-free loans and execute an “exit strategy” to buy back their donations at a significantly discounted rate. In some instances, Meyer backdated documents so that clients could claim purported donations on their prior years’ tax returns. Over the years, Meyer ignored a chorus of people who advised him that his plan was illegal, including the IRS. Indeed, the IRS conducted several audits of Meyer’s charities, and found that the Ultimate Tax Plan was an economic sham. Meyer signed documents acknowledging that finding and agreeing to close the bogus charities. However, Meyer simply created new “charities” and continued to promote his illegal shelter to wealthy taxpayers. In April 2018, the Justice Department filed a civil suit against Meyer seeking to enjoin him from continuing to promote the Ultimate Tax Plan. As part of that litigation, the Justice Department issued civil subpoenas to Meyer’s clients requesting records related to the Ultimate Tax Plan. In response, Meyer created false, backdated documents, and directed clients to submit them to the Justice Department. Meyer also provided false, backdated documents in response to document demands he directly received from the Justice Department. In April 2019, a federal district court permanently enjoined Meyer from organizing, promoting, marketing or selling the Ultimate Tax Plan. Meyer earned more than $10 million from selling the Ultimate Tax Plan. He used that income to purchase a multi-million-dollar estate and a luxury vehicle collection that included Lamborghinis, Rolls Royces, Mercedes-Benzes, a Bentley and a Ferrari. In addition to his prison sentence, U.S. District Judge Moore for the Southern District of Georgia ordered Meyer to serve three years of supervised release. The court will determine restitution at a later date. Rao Garuda and Cullen Fishel both pleaded guilty in the Northern District of Ohio to conspiracy to defraud the United States and are scheduled to be sentenced on April 16. Acting Deputy Assistant Attorney General Stuart M. Goldberg of the Justice Department’s Tax Division made the announcement. The Tax Division thanks U.S. Attorney Markenzy Lapointe for the Southern District of Florida for his office’s assistance. IRS Criminal Investigation (CI) investigated the case. Assistant Chief Michael Boteler and Trial Attorneys Andrew Ascencio and Michael Jones of the Tax Division are prosecuting the case. CI is the criminal investigative arm of the IRS, responsible for conducting financial crime investigations, including tax fraud, narcotics trafficking, money-laundering, public corruption, healthcare fraud, identity theft and more. CI special agents are the only federal law enforcement agents with investigative jurisdiction over violations of the Internal Revenue Code, obtaining a more than a 90 percent federal conviction rate. The agency has 20 field offices located across the U.S. and 12 attaché posts abroad.
