Case Documentl File?gzl?? Page 10f 10

IN THE UNITED STATES DISTRICT COURT I I
FOR THE WESTERN DISTRICT OF APR '1 2018

CLERK U.S. DISTRICT COURT
WEST. DIST. OF 

Criminal No. (0 7

UNITED STATES OF AMERICA

V.
(26 U.S.C. 7201 and 7203)
LOREN PULLIAM
INDICTMENT
The grand jury charges:

At all times material to this Indictment, unless otherwise alleged:
INTRODUCTORY ALLEGATIONS

l. The defendant, LOREN PULLIAM was a resident of the Western
District of PULLIAM was a certi?ed registered nurse anesthetist and
held a master?s degree in nursing.

2. The Internal Revenue Service (IRS) is and was an agency of the United States
Department of the Treasury. The IRS haS responsibility for the ascertainment, computation,
assessment, and collection of taxes, including federal income taxes.

3. A Form iS and was an information return that an employer uses to
report to the IRS income paid to independent contractors. Generally, businesses must issue Forms
1099-MISC to any individual who receives $600 or more during the year.

4. From 2002 through at least 2014, PULLIAM, a CRNA, worked as an independent
contractor at various hospitals and surgery centers. As an independent contractor, PULLIAM was
required to ?le U.S. Individual Income Tax Returns, Forms 1040, (?tax returns?) to report the
income She earned working as a CRNA, as well as any other income She earned, to the IRS.

However, PULLIAM failed to timely ?le tax returns for those years. PULLIAM untimely filed

 

 

 

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tax returns for 2002 through 2006 and, after being noti?ed she was under criminal investigation,
untimely ?led tax returns for 2008 through 2014. PULLIAM has never ?led a return for 2007.

5. On her delinquently??led tax retums for the 2002-2006 and 2008?2014 years,
PULLIAM reported that she owed federal income taxes. However, PULLIAM failed to pay all
taxes due and owing to the IRS for those years.

6. In and around December 2004, the IRS initiated an examination of 
2002 tax year. In and around March 2007, the IRS expanded its examination to include Pulliam?s
2003 through 2005 tax years. Using the income reported to the IRS by her employers on Forms
1099, which totaled more than $500,000 for the years 2002 through 2005, the IRS prepared
substitutes for returns for 2002 through 2005.

7. LJ Enterprises, LLC, also known as Enterprises, Inc. Enterprises?) was
a nominee entity that PULLIAM formed in the Commonwealth of in or around June
2006.

8. In and around August 2006, PULLIAM opened a bank account in the name of LI 
Enterprises. PULLIAM had signature authority over the account. PULLIAM deposited her
income into the LJP Enterprises bank account. She then used that account for the payment of
personal expenses.

9. Beginning in and around 2007, PULLIAM instructed her employers to issue Forms
to LJ Enterprises. Enterprises has never ?led an income tax return with the IRS.

10. On or about September 18, 2008, in a consent order entered by the United States
Tax Court, PULLIAM agreed she owed approximately $281,149 in tax and penalties for the tax

years 2002 through 2005 plus penalties which continued to accrue for 2004 and 2005.

 

 

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11. Despite earning over $1.2 million in total compensation for her work as a CRNA
during the years 2008 through 2016, PULLIAM failed to pay the tax due and owing for the years
2002-2005.

12. Beginning in 2010, due to failure to pay to the IRS the tax due and
owing for the 2002-2005 tax years and her failure to ?le her individual federal income tax returns
for subsequent years, the IRS initiated additional collection activity in an effort to collect the
unpaid tax liabilities. The efforts included, but were not limited to, issuing notices of intent
to levy against one or more of bank accounts and issuing a notice of intent to levy on
wages paid by LJP Enterprises to PULLIAM. PULLIAM was sent copies of these notices, which
notices speci?ed the tax years and the amounts due.

13. From approximately 201 1 through 2014, PULLIAM continued to work as a CRNA.
PULLIAM received adjusted gross income in the following approximate amounts: $159,866 in
2011; $75,186 in 2012; $159,107 in 2013; and $110,099 in 2014. PULLIAM failed to pay the

taxes due on these amounts.

 

 

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mm
(26 U.S.C. 7201 Evasion of Payment of Income Tax)
The grand jury further charges that:
14. The factual allegations of Paragraphs 1 through 13 are re-alleged and incorporated
by reference as if fully set forth herein.
15. Beginning in and around 2003, and continuing until on or about April 10, 2018, in
the Western District of and elsewhere, the defendant, LOREN PULLIAM, did
willfully attempt to evade and defeat the payment of income tax, interest, and penalties due and
owing by her to the United States of America for the calendar years 2002 through 2005, by
committing the following af?rmative acts, among others:
a. Creating and causing the entity LJ Enterprises to serve as her nominee
and alter ego;
b. Directing third parties to pay her compensation to Enterprises;
c. Depositing income into, and causing income to be deposited into, a bank
account held in the name of LJ Enterprises;
d. Paying personal expenses from a bank account held in the name of 
Enterprises; and
e. Keeping her personal checking account balance at minimal levels.

In violation of Title 26, United States Code, Section 7201.

 

 

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COUNT TWO
(26 U.S.C. 7201 Evasion of Assessment of Income Tax 2011)

The grand jury further charges that:

16. The factual allegations of Paragraphs 1 through 13 are re-alleged and incorporated
by reference as if fully set forth herein.

17. During the calendar year 2011, the defendant, LOREN PULLIAM, received
taxable income, upon which there was income tax due and owing to the United States of America.
Knowing the foregoing facts and failing to make an income tax return, on or before April 16, 2012,
as required by law, to any proper of?cer of the Internal Revenue Service, and to pay income tax
to the Internal Revenue Service, LOREN PULLIAM, beginning in and around January 2011 and
continuing until on or about December 23, 2015, in the Western District of and
elsewhere, willfully attempted to evade and defeat the assessment of income tax due and owing by
her to the United States of America, for the calendar year 2011, by committing the following
affirmative acts, among others:

a. Causing third parties to pay her compensation to LJ Enterprises;

b. Depositing income into, and causing income to be deposited into, a bank
account held in the name of LJ Enterprises; and

c. Paying personal expenses from a bank account held in the name of 
Enterprises.

In violation of Title 26, United States Code, Section 7201.

 

 

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COUNT THREE
(26 U.S.C. 7201 Evasion of Assessment of Income Tax - 2012)

The grand jury further charges that:

18. The factual allegations of Paragraphs 1 through 13 are re?alleged and incorporated
by reference as if fully set forth herein.

19. During the calendar year 2012, the defendant, LOREN PULLIAM, received
taxable income, upon which there was income tax due and owing to the United States of America.
Knowing the foregoing facts and failing to make an income tax return, on or before April 15, 2013,
as required by law, to any proper of?cer of the Internal Revenue Service, and to pay income tax
to the Internal Revenue Service, LOREN PULLIAM, beginning in and around January 2012 and
continuing until on or about December 23, 2015, in the Western District of and
elsewhere, willfully attempted to evade and defeat the assessment of income tax due and owing by
her to the United States of America, for the calendar year 2012, by committing the following
af?rmative acts, among others:

a. Causing third parties to pay her compensation to Enterprises;

b. Depositing income into, and causing income to be deposited into, a bank
account held in the name of Enterprises; and

c. Paying personal expenses from a bank account held in the name of 
Enterprises.

In violation of Title 26, United States Code, Section 7201.

 

 

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COUNT FOUR
(26 U.S.C. 7201 Evasion of Assessment of Income Tax 2013)

The grand jury further charges that:

20. The factual allegations of Paragraphs 1 through 13 are re-alleged and incorporated
by reference as if fully set forth herein.

21. During the calendar year 2013, the defendant, LOREN PULLIAM, received
taxable income, upon which there was income tax due and owing to the United States of America.
Knowing the foregoing facts and failing to make an income tax return, on or before April 15, 2014,
as required by law, to any proper officer of the Internal Revenue Service, and to pay income tax
to the Internal Revenue Service, LOREN PULLIAM, beginning in and around January 2013 and
continuing until on or about December 23, 2015, in the Western District of and
elsewhere, willfully attempted to evade and defeat the assessment of income tax due and owing by
her to the United States of America, for the calendar year 2013, by committing the following
af?rrnative acts, among others:

a. Causing third parties to pay her compensation to LJ Enterprises;

b. Depositing income into, and causing income to be deposited into, a bank
account held in the name of LJ Enterprises; and

c. Paying personal expenses from a bank account held in the name of LJ 
Enterprises.

In violation of Title 26, United States Code, Section 7201.

 

 

 

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COUNT FIVE
(26 U.S.C. 7201 Evasion of Assessment of Income Tax 2014)

The grand jury further charges that:

22. The factual allegations of Paragraphs 1 through 13 are re-alleged and incorporated
by reference as if fully set forth herein.

23. During the calendar year 2014, the defendant, LOREN PULLIAM, received
taxable income, upon which there was income tax due and owing to the United States of America.
Knowing the foregoing facts and failing to make an income tax return, on or before April 15, 2015,
as required by law, to any proper of?cer of the Internal Revenue Service, and to pay income tax
to the Internal Revenue Service, LOREN PULLIAM, beginning in and around January 2014 and
continuing until on or about October 21, 2016, in the Western District of and
elsewhere, willfully attempted to evade and defeat the assessment of income tax due and owing by
her to the United States of America, for the calendar year 2014, by committing the following
af?rmative acts, among others:

a. Causing third parties to pay her compensation to LJ Enterprises;

b. Depositing income into, and causing income to be deposited into, a bank
account held in the name of LJ Enterprises; and

c. Paying personal expenses from a bank account held in the name of 
Enterprises.

In violation of Title 26, United States Code, Section 7201.

 

 

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COUNTS SIX THROUGH NINE
(26 U.S.C 7203 Failure to File Tax Returns and Failure to Pay Taxes)

The grand jury further charges that:

24. The factual allegations of Paragraphs 1 through 13 are re?alleged and incorporated
by reference as if fully set forth herein.

25. During the calendar years set forth below, the defendant, LOREN PULLIAM, had
received adjusted gross income in the approximate amounts set forth below, on which taxable
income there was owing to the United States of America an income tax in the approximate amounts
set forth below. By reason of her gross income, LOREN PULLIAM was required by law,
following the close of the calendar year, and on or before the due dates set forth below, to make
an income tax return to any proper of?cer of the Internal Revenue Service, stating speci?cally the
items of her gross income and any deductions and credits to which she was entitled. LOREN
PULLIAM was further required to pay the income tax to the Internal Revenue Service Center, at
Pittsburgh, to a person assigned to receive returns at the local of?ce of the Internal
Revenue Service at Pittsburgh, or to another Internal Revenue Service of?ce
permitted by the Commissioner of Internal Revenue. Well knowing all of the foregoing, LOREN
PULLIAM did willfully fail, on or about the due dates set forth below, in the Western District of

and elsewhere, to make an income tax return and to pay the income tax due.

 

 

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COUNT CALENDAR APPROXIMATE APPROXIMATE APPROXIMATE
YEAR DUE DATE OF AMOUNT OF AMOUNT OF
RETURN ADJUSTED INCOME TAX
GROSS DUE
INCOME
SIX 2011 April 16, 2012 $159,866 $53,015
SEVEN 2012 April 15,2013 $75,186 $22,038
EIGHT 2013 April 15, 2014 $159,107 $54,310
NINE 2014 April 15, 2015 $110,099 $28,314

 

In Violation of Title 26, United States Code, Section 7203.

MM

SCOTT W. BRADY
United States Attorney
PA ID No. 88352

  

Foreperson