Department of the Treasury responsible for enforcing and administering the tax laws of theUnited States and collecting taxes owed to the United States.
(Conspiracy to Defraud the United States)
The factual allegations contained in Paragraphs 1 through 6 of the IntroductionSection of this Indictment are realleged and incorporated herein as if copied verbatim.
From in or about January 2006, the exact date being unknown to the Grand Jury,and continuing to on or about the date of this Indictment, within the Middle District of Alabama
and elsewhere, defendant JAMES TIMOTHY TURNER, "B.H.," "T.F.," "K.F.," "M.E.," and
others, known and unknown to the Grand Jury, unlawfully, voluntarily, intentionally, andknowingly did conspire, combine, confederate, and agree together and with each other, todefraud the United States for the purpose of impeding, impairing, obstructing, and defeating thelawful government functions of the IRS in the ascertainment, computation, assessment, andcollection of federal income taxes.MANNER AND MEANS
To accomplish the objects of this scheme, Defendant JAMES TIMOTHYTURNER and his co-conspirators used the following manners and means, among others:A.Defendant JAMES TIMOTHY TURNER and others would and did, forfinancial gain, promote and charge participants for attending "seminars" held throughout thecountry at which he taught attendees how to defraud the IRS and other federal entities.B.Defendant JAMES TIMOTHY TURNER and others would and did create,prepare, file, and cause to be filed, with the United States Department of the Treasury, the IRS,and other federal entities, false, fictitious, and fraudulent financial instruments and other
Case 1:12-cr-00169-MHT-WC Document 1 Filed 09/12/12 Page 2 of 11