Case 1:18-cr-00276-CCB Document 1 Filed 05/08/18 Page 1 of 3
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ItCEMD

MAY

UW IDEH/SRD USAO# 2018ROO 181

8 2018

IN THE UNITED STATES DISTRICT COURT
. FOR THE DISTRICT OF MARYLAND

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UNITED STATES OF AMERICA

v.
DARRYL DE SOUSA,
Defendant

UNDER SEAL
Criminal No.

~6-IR- O(}.7

(Failure to File a Federal Return,
26 U.S.C. ~ 7203)

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INFORMA nON
The United ~tates Attorney for the District of Maryland charges:
COUNT 1
(Failure to File a 2013 U.S. Individual Income Tax Return)
During calendar year 2013, the defendant,
DARRYL DE SOUSA,
who was a resident of Baltimore, Maryland, had and received gross income of at least $93,104.
By reason of such gross income, he was required by law; following the close of calendar year
2013, and on or before April 15, 2014, to make an income tax return to the Internal Revenue
Service Center, at Andover, Massachusetts, to a person assigned to receive returns at the local
office of the Internal Revenue Service at Baltimore, Maryland, or to another Internal Revenue
Service office permitted by the Commissioner oflnternal Revenue, stating specifically the items
of his gross income and any deductions and credits to which he was entitled. Well knowing and
believing all of the foregoing, he did willfully fail, on or about April 15, 2014, in the District of
Maryland and elsewhere, to make an income tax return.
In violation of26 U.S.c.

S 7203.

I'd

 Case 1:18-cr-00276-CCB Document 1 Filed 05/08/18 Page 2 of 3

COUNT 2
(Failure to File a 2014 U.S. Individual Income Tax Return)
During calendar year 2014, the defendant,
DARRYL DE SOUSA,
who was a resident of BaItimore, Maryland, had and received gross income of at least $101,985.
By reason of such gross income, he was required by law, following the close of calendar year
2014, and on or before April 15, 2015, to make an income tax return to the Internal Revenue
Service Center, at Andover, Massachusetts, to a person assigned to receive returns at the local
office of the Internal Revenue Service at Baltimore, Maryland, or to another Internal Revenue
Service office permitted by the Commissioner of Internal Revenue, stating specifically the items
of his gross income and any deductions and credits to which he was entitled. Well knowing and
believing all of the foregoing, he did willfully fail, on or about April 15,2015, in theDistrict of
Maryland and elsewhere, to make an income tax return.
In violation of26 U.S.C.

S 7203.

2

 Case 1:18-cr-00276-CCB Document 1 Filed 05/08/18 Page 3 of 3

COUNT 3
(Failure to File a 2015 U.S. Individual Income Tax Return)
During calendar year 2015, the defendant,
DARRYL DE SOUSA,
who was a resident of Baltimore, Maryland, had and received gross income of at least $127,089.
By reason of such gross income, he was required by law, following the close of calendar year
2015, and on or before April 15,2016, to make an income tax return to the Internal Revenue
Service Center, at Andover, Massachusetts, to a person assigned to receive returns at the local
office of the Internal Revenue Service at Baltimore, Maryland, or to another Internal Revenue
Service office permitted by the Commissioner ofinternal Revenue, stating specifically the items
of his gross income and any deductions and credits to which he was entitled. Well knowing and
believing all of the foregoing, he did willfully fail, on or about April 15, 2016, in the District of
Maryland and elsewhere, to make an income tax return.
In violation of26 U.S.C.

S 7203.

R~

O<.IJiw../~/l.)

United States Attorney

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