U.S. Eleventh Circuit - The FindLaw 11th Circuit Court of Appeals Opinion Summaries Blog

11th Cir. Affirms Convictions Against 'Kingdom of Heaven' Tax Cheat

The Eleventh Circuit affirmed a lower federal district's conviction of Ronald Francis Croteau who was convicted of several tax crimes in 2015. It seems to be the end of the line as far as appeals go for the self-proclaimed "Ambassador to the Kingdom of Heaven."

Croteau plied his magic touch to filing ten fraudulent tax returns between 2008 and 2010 -- with claimed refunds totaling more than $3.8 million.

$3.8 Million in Fraudulent Tax Refunds

Croteau filed -- interestingly -- over ten fraudulent tax returns and claimed refunds that topped nearly $4 million dollars. Croteau unlawfully claimed several tax withholdings from fraudulent 1099-OID forms that were ostensibly issued by financial institutions. When the IRS got wind of Croteau's frivolous tax returns, he decided to continue on anyway. Alongside the fraudulent returns, Croteau also stymied the IRS by filing false liens against IRS employees and other fraudulent claims in an attempt to loosen his tax liabilities.

When presented to the court, evidence indicated that Croteau had gotten into a tax fraud scheme soon after he was hospitalized in a car accident. Immediately after the crash, his wife left him. Somehow, he got involved in a fringe tax protest group known as the Little Tribe of Pembina Nation. It was from this group that he happened upon a bogus theory that the United States is a corporation and the taxpayers its employees -- hence the false 1099-OID forms.

Challenging the Reasonableness

Croteau sought to challenge the reasonableness of the district court slapping him with 56 months of prison for his crimes; he also petitioned the court for a "downward variance" of his sentence. But the penalty imposed by the district court was deemed to be reasonable by the circuit court and well within the advisory range. In fact, given the magnitude of Croteau's crimes, he could have "reasonably" served 53 years, taking into account the totality of the circumstances.

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