Client of Fraudulent Tax Shelter Scheme Pleads Guilty to Obstruction

An Ohio doctor pleaded guilty today to corruptly endeavoring to obstruct the due administration of the internal revenue laws.

According to court documents and statements made in court, Dr. Suman Jana, of Strongsville, was a client of fraudulent tax shelter promoter Michael Meyer and his sub-promoter Rao Garuda. Dr. Jana used Meyer’s scheme, the “Ultimate Tax Plan,” to fraudulently claim $764,350 in charitable contribution tax deductions for tax years 2012 through 2015. Meyer and his co-conspirators marketed the scheme as a way for high-income clients to reduce their taxes by claiming they had donated valuable property to charities Meyer controlled, while in reality retaining complete control and use over their “donated” assets. Clients, such as Dr. Jana, were able to use the funds in the purported charities’ accounts to pay for personal expenses. In fact, Dr. Jana used the funds he claimed to have donated to charity to, among other things, purchase several cars for him and his wife.

On Jan. 5, 2017, after claiming five years-worth of charitable contribution tax deductions, Dr. Jana bought back the company he had “donated” to Meyer’s charity for $10,000 — reclaiming his purported donation and exiting the plan.

On April 3, 2018, the Justice Department filed a civil complaint for permanent injunction against Meyer in U.S. district court. On May 24, 2018, the Justice Department served a civil subpoena on Dr. Jana requesting that he produce records in connection with the Ultimate Tax Plan. In response to the subpoena, Meyer and Garuda instructed Dr. Jana to pretend that the buyback did not occur. Meyer prepared backdated transaction documents, written acknowledgements and promissory notes for Dr. Jana to sign and submit in response to the civil subpoena. The false documents were created to make it look as if Dr. Jana signed the promissory notes at the time that he and his wife paid personal expenses out of the purported charity.

In June 2018, Dr. Jana signed the false documents and sent them to the Justice Department in response to the civil subpoena.

Dr. Jana is scheduled to be sentenced on March 7, 2025, and faces a maximum penalty of three years in prison. He also faces a period of supervised release, restitution and monetary penalties. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

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 investigated the case.

Assistant Chief Michael Boteler and Trial Attorney Andrew Ascencio of the Tax Division are prosecuting the case.