ARTICLE
3 October 2025

Three Recent U.S. Tax Evasion Prosecutions: Bitcoin, Payroll Taxes, And Yoga Empire

RS
Rotfleisch & Samulovitch P.C.

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Rotfleisch Samulovitch PC is one of Canada's premier boutique tax law firms. Its website, taxpage.com, has a large database of original Canadian tax articles. Founding tax lawyer David J Rotfleisch, JD, CA, CPA, frequently appears in print, radio and television. Their tax lawyers deal with CRA auditors and collectors on a daily basis and carry out tax planning as well.
Recent IRS tax evasion prosecutions reflect how diverse misconduct—from sophisticated crypto concealment to failure to remit payroll taxes and repeated non-filing—can result in serious legal consequences.
United States Tax
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Overview – IRS tax evasion cases

Recent IRS tax evasion prosecutions reflect how diverse misconduct—from sophisticated crypto concealment to failure to remit payroll taxes and repeated non-filing—can result in serious legal consequences.

These cases, widely publicized through DOJ and IRS press releases and amplified in news outlets, offer instructive contrasts on how willfulness, concealment tactics, and the mechanism of evasion shape tax evasion penalties.

Cryptocurrency Tax Evasion: Frank Richard Ahlgren III

Frank Richard Ahlgren III, an early Bitcoin investor from Austin, Texas, pleaded guilty in September 2024 to filing false returns that underreported over $4 million in Bitcoin sales between 2017 and 2019—leading to a tax loss exceeding $1 million.

In December 2024, he was sentenced to two years in prison, one year of supervised release, and ordered to pay $1,095,031 in restitution. The case was publicized via Department of Justice and IRS-Criminal Investigation press releases, emphasizing the significance of the first criminal tax evasion prosecution centered solely on cryptocurrency.

Payroll Trust-Fund Tax Evasion: Luis E. Perez

Luis E. Perez, owner of several Orange County, California staffing companies, pleaded guilty in September 2024 to evading the payment of nearly $30 million in payroll and trust-fund taxes. In May 2025, he received an eight-year prison sentence (96 months) and was ordered to pay $38,052,767 in restitution. The prosecution was widely disseminated through IRS press statements, with headlines highlighting the "astonishing" duration and scope of the scheme.

Non-Filing & Lifestyle Evasion: Gregory Gumucio

Gregory Gumucio, the founder of "Yoga to the People," failed to file personal or business tax returns despite earning nearly $3.5 million between 2012 and 2020. He pleaded guilty in October 2024 and, in June 2025, was sentenced to four years in prison plus three years of supervised release, and ordered to pay $2,729,407.10 in restitution. Media reports noted that he owed more than $2.5 million in unpaid taxes and lived extravagantly, reinforcing public interest via AP and DOJ announcements.

Similarities Across the Cases

All three prosecutions involve:

  • Multi-year conduct resulting in significant tax loss.
  • Demonstrable financial benefit and willful misconduct.
  • Publicity through official channels—IRS-CI and DOJ press releases, followed by mainstream media coverage—which underscores IRS enforcement priorities and deters similar conduct.

In each, prosecutors relied on documentary evidence, forensic accounting, and intent demonstration. Media coverage helped shape public awareness and policy discourse, and is part of the IRS policy of name and shame.

Differences in Conduct and Exposure

  • Ahlgren's case involved technical concealment—blockchain obfuscation, mixers, and inflated cost basis—highlighting how an experienced U.S. tax lawyer must navigate emerging technologies in evidentiary strategy and how the IRS and Department of Justice have sophisticated investigation tools with respect to blockchain technology.
  • Perez's payroll-tax case underscores that misappropriation of withholdings (trust-fund taxes) provokes particularly harsh penalties due to the fiduciary nature of those funds. A seasoned U.S. tax attorney would prioritize addressing such liabilities promptly.
  • Gumucio's non-filing and lifestyle case demonstrates that repeated non-filing, false representations (including fabricated returns to third parties), and lavish spending can support a willfulness narrative even absent complex schemes. A top U.S. tax lawyer would emphasize early remediation and voluntary disclosure to mitigate criminal risk.

Pro-Tax Tips

Consult with expert U.S. tax counsel early if you have unreported gains, unpaid payroll withholdings, or years of non-filing. Maintain accurate, contemporaneous records—especially for cryptocurrency sales, with exchange statements, wallet logs, and cost basis documentation. When payroll trust-fund taxes are involved, treat those as paramount liabilities since it is not your money.

Explore voluntary disclosure or civil resolution programs before criminal referrals are made; proactive remediation often reduces enforcement severity. Engaging an experienced U.S. tax lawyer can help structure effective disclosure, negotiate payment plans, and shift outcomes from criminal exposure toward civil resolution.

Frequently Asked Questions

What are typical penalties in these types of prosecutions?

Penalties vary widely: Ahlgren—two years plus restitution; Perez—eight years plus over $38 million restitution; Gumucio—four years, supervised release, and about $2.7 million restitution.

How are these cases made public?

They're typically publicized via coordinated DOJ and IRS-Criminal Investigation press releases, followed by coverage in media outlets such as AP and Reuters.

Can early disclosure prevent criminal charges?

While not guaranteed, early and voluntary correction of non-compliance, with top U.S. tax lawyer guidance, often reduces the likelihood of criminal referral and may enable favorable civil tax settlements.

Is crypto treatment different from other assets?

No—crypto gains are taxable like any capital asset—but its digital nature means robust record-keeping is essential, and obfuscation may undermine credibility with investigators.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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