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You're listening to Final Notice.
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Real tax cases exposed with Jason Carr.
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Each week we break down real Department of Justice tax fraud prosecutions and reveal what should have been done to avoid them.
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And now here's your host, Jason Carr.
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She kept the books for a Jackson Hole hospitality business while working from Hawaii.
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Nearly one and a half million dollars went missing.
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In the accounting system, transfers to her own accounts appeared as supplies and invoices.
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Laura Marie Means was a bookkeeper for a family business in Jackson Hole, Wyoming.
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The business owned several lodging and hospitality properties.
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It hired her in late 2015 and gave her control over employee payroll, bank accounts, and tax reporting.
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If you run a business, you know why that role matters.
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A bookkeeper sees the ordinary movement of money before anyone else does.
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Wages go out, vendors get paid, bank balances change, tax information gets assembled.
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When something doesn't match, the bookkeeper is often the person who finds it.
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In this case, Means was also the person moving the money.
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She relocated to Hawaii in 2019.
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Her employer let her continue working remotely on the condition that she return to Jackson once a month.
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According to the government's account of the case, the theft began in February of that year, shortly after the move and continued through September 2025.
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The distance makes this case distinctive, but the underlying problem was closer to home.
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The same person could handle payments and explain those payments in the books.
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By the time the case reached federal court, Means had pled guilty to wire fraud and filing a false tax return.
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On September 22nd, 2026, a judge sentenced her to 46 months in prison, followed by three years of supervised release.
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He also ordered her to pay$1,484,104.80 to her former employer and$355,875.32 to the IRS.
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46 months for transactions that in the books were made to look routine.
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The first thing to understand is that Means did not need to make the business disappear.
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She needed unauthorized payments to resemble payments the business already made.
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A hotel business buys supplies, it receives invoices, it runs payroll.
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Its bank accounts move money every day.
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Those ordinary transactions gave her places to hide extraordinary ones.
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The government says Means altered QuickBooks entries so transfers into her personal accounts appeared to be standard business expenses, including supplies or invoices.
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She also used a separate bank account the business had not approved to divert company funds.
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There was another route, compensation.
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Means issued herself unauthorized payments, including duplicate salary payments and bonuses she had not earned.
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Consider what that looks like if you're reviewing the business from a distance.
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Supplies cost more than expected.
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An invoice gets paid.
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Payroll increases.
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Each has a possible explanation.
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Hospitality expenses move around.
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Staffing needs change.
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The question is whether anyone independently checked the explanation.
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Who was the supplier?
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What was delivered?
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Who approved the bonus?
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Why was there another salary payment?
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Who opened the separate account and why did company money enter it?
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The government's account says means control payroll, bank accounts, and tax reporting.
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That combination let the payments and their descriptions travel through the same hands.
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The remote arrangement let her keep managing those transactions electronically from Hawaii.
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The government charged wire fraud because the fraudulent transfers moved through interstate electronic communications.
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Then came the tax side.
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A person who takes money from an employer has received money, whatever the employer's books call the payment.
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The government says Means concealed the stolen income and filed false tax returns.
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Her federal guilty plea included one count of filing a false return.
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So there were two accounts of the same money.
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The business records called it an expense or compensation.
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Means tax reporting did not tell the full story of what she received.
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This is how an embezzlement case acquired its tax charge.
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So where was the criminal line?
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Start with the business.
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A mistaken expense category can be fixed.
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An accidental duplicate paycheck can be reversed.
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The conduct described here was a years-long series of unauthorized transfers, altered accounting entries, an unapproved account, duplicate pay, and unearned bonuses.
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For the tax case, the line was the false return.
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The government says means received money she had taken from the business, concealed that income, and filed false returns.
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A signed return matters because it's the taxpayer statement to the IRS about the year.
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Section 7206, Subsection 1 addresses willfully making a return under penalties of perjury that the signer does not believe is true as to a material matter.
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The theft created one victim.
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The false return created another.
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Here is what makes this an investigative story.
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The money had to move through records.
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The government identifies four parts of the trail: the accounting entries, transfers into means own accounts, the separate unauthorized bank account, and payments to herself through payroll.
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Put those pieces next to one another.
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An entry says supplies.
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The transfer went to an account means controlled.
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A payment says salary.
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The payroll history shows another salary payment.
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A bonus appears.
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Where's the approval?
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You do not need a dramatic confession to understand why those comparisons matter.
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And yet there is a limit to what I can say about this investigation.
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Court documents identifies the conduct and the records involved.
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It does not identify the first transaction someone questioned, say precisely how investigators discovered the separate account, or name a single entry as the decisive exhibit.
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I'm not going to invent that moment.
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What the court records do show is enough to explain the case.
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Descriptions in the books were compared with the actual movement of company money, and the government said those descriptions concealed payments to the bookkeeper.
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Then the tax question follows the money one step farther.
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What reach means?
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What did she report?
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The government says the stolen receipts were concealed and her returns were false.
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IRS criminal investigation, the FBI, and the Teton County Sheriff's Office investigated.
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That mix makes sense.
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The records concern both the business theft and tax reporting.
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The recurring document in this story is the accounting entry.
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A line labeled invoice seems dull.
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That is precisely why it deserves attention.
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The label tells the owner what the bookkeeper says happened.
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The bank transfer tells the owner where the money actually went.
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The government says means used expense labels for unauthorized transfers to her personal accounts.
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An owner reviewing only the expense category gets half the answer.
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The other half is the receiving account.
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The tax rule behind this case is simple.
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Illegal gains can be taxable income.
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Section 61 defines gross income broadly.
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Treasury Regulation Section 1.61-14A specifically says illegal gains constitute gross income.
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The employer might call a transfer of supplies.
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The recipient might wish it had been ordinary pay.
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The tax question still begins with what the person actually received.
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In Mean's case, the government says she can still stolen income and filed false returns.
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The court ordered more than$355,000 in restitution for these actions to the IRS.
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The practical takeaway: when the books in the bank disagree, follow the bank.
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There's another bookkeeper case that makes one point especially well.
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In United States vs.
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Penguin, an office manager used QuickBooks to send herself extra payments.
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Later, she marked those transactions as void.
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The payments remained in the transaction history, and an accountant reviewing the records identified them.
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That was a separate wire fraud case.
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I'm using it for one narrow comparison.
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Changing an accounting label does not undo a bank payment.
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Means reported method used different labels.
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The principle for anyone reviewing a business is the same.
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Look past the category and see where the funds landed.
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At this point, there were two paths for Means.
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If she was entitled to a raise, a bonus, or reimbursement, there was a straightforward way to get it.
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Request approval, document the payment, put it through the proper account, and report it correctly.
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If money had already been taken without approval, the next step was to stop, preserve the records, and get privileged advice before creating another explanation or filing another return.
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Instead, the government describes a pattern that continued for years: disguised transfers, an unauthorized account, duplicate salaries, unearned bonuses, and false returns.
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The longer that pattern continued, the more records there were to compare.
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I want to look at this from both sides of the desk because the person hearing this episode may be a business owner who trusts a bookkeeper or a tax professional reviewing a client's books.
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If the owners had come to me with unexplained payments, I would begin by preserving the accounting and bank records.
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Then I would ask for a transaction level reconciliation.
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Show me each payment label supplies or invoices.
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Show me the underlying invoice.
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Show me the person who approved it.
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Show me the destination account.
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And then do the same for bonuses, payroll adjustments, and reimbursements.
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I would also identify every business bank account and every authorized signer.
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In this case, the government says means use an account the business had not approved.
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An owner cannot meaningfully review cash if the list of company accounts itself is incomplete.
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Next, I would change the process.
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The person who enters a payment should not be its only approver and its only reviewer.
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An owner or independent person should review changes to pays, new bank accounts, bonuses, and unusual transfers against bank statements the reviewer obtains independently.
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That is an operational control.
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It's also a tax control.
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A business should absolutely know whether the expense entry is flowing into its tax work describe expenses it actually incurred.
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If prior business filings use incorrect records, the owners would need to determine which filings were affected and correct them as appropriate.
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I would not assume that means personal false return charge tells us what appeared on every return filed by that business.
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That is a separate records review.
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For a tax preparer or CPA, I would focus on contradictions.
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If a client's general ledger says supplies, but the bank record shows a transfer to an employee, ask what happened.
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There may be an authorized reimbursement, there may be an error, there may be something more serious.
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The answer needs support before it goes into a return.
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Now consider mean side.
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If a person had taken company funds, the issue goes well beyond preparing a corrected return.
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Counsel needs to evaluate the underlying conduct, the tax years, the records, and communications with the employer and government together.
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While I do civil tax resolution work, a case like this involving theft also requires criminal defense coordination.
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There's a distinction worth making here.
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The IRS has a voluntary disclosure practice for certain willful tax noncompliance, but its guidance says the practice does not apply to taxpayers with a legal source income.
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It would be wrong to promise someone in Means position that this procedure offers a clean route out of prosecution.
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My advice at the earliest point would be direct: stop the unauthorized payments, preserve what happened, and get advice before adding a false record to an already serious problem.
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Means had the access a hospitality business gave its bookkeeper so the business could operate.
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The government says she used that access to divert nearly$1.5 million, disguise transfers in the books, and conceal the stolen income on tax returns.
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She received a 46-month prison sentence and restitution orders to both the business and the IRS.
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Here is the lesson.
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An expense description tells you what someone called a payment.
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It does not tell you who got the money.
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I'm Jason Carr, tax attorney.
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If you want to make sure you never end up on this podcast, you know where to find me.
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Cartaxlaw.com.
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Link is in the show notes.
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This has been Final Notice, Real Text Cases Exposed.
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If you enjoyed today's episode, share it with a friend or colleague who needs to hear it.
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Subscribe so you never miss a case.
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For show notes and more, visit cartaxlaw.com.
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This podcast is legal education and commentary, not legal advice.
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And listening does not create an attorney client relationship.
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Full disclaimer at Cartaxlaw.com.
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You're listening to Final Notice.
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Real tax cases exposed with Jason Carr.
00:00:12.720 --> 00:00:20.719
Each week we break down real Department of Justice tax fraud prosecutions and reveal what should have been done to avoid them.
00:00:21.039 --> 00:00:23.839
And now here's your host, Jason Carr.
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She kept the books for a Jackson Hole hospitality business while working from Hawaii.
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Nearly one and a half million dollars went missing.
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In the accounting system, transfers to her own accounts appeared as supplies and invoices.
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Laura Marie Means was a bookkeeper for a family business in Jackson Hole, Wyoming.
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The business owned several lodging and hospitality properties.
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It hired her in late 2015 and gave her control over employee payroll, bank accounts, and tax reporting.
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If you run a business, you know why that role matters.
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A bookkeeper sees the ordinary movement of money before anyone else does.
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Wages go out, vendors get paid, bank balances change, tax information gets assembled.
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When something doesn't match, the bookkeeper is often the person who finds it.
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In this case, Means was also the person moving the money.
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She relocated to Hawaii in 2019.
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Her employer let her continue working remotely on the condition that she return to Jackson once a month.
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According to the government's account of the case, the theft began in February of that year, shortly after the move and continued through September 2025.
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The distance makes this case distinctive, but the underlying problem was closer to home.
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The same person could handle payments and explain those payments in the books.
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By the time the case reached federal court, Means had pled guilty to wire fraud and filing a false tax return.
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On September 22nd, 2026, a judge sentenced her to 46 months in prison, followed by three years of supervised release.
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He also ordered her to pay$1,484,104.80 to her former employer and$355,875.32 to the IRS.
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46 months for transactions that in the books were made to look routine.
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The first thing to understand is that Means did not need to make the business disappear.
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She needed unauthorized payments to resemble payments the business already made.
00:02:29.439 --> 00:02:34.400
A hotel business buys supplies, it receives invoices, it runs payroll.
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Its bank accounts move money every day.
00:02:36.960 --> 00:02:41.599
Those ordinary transactions gave her places to hide extraordinary ones.
00:02:41.840 --> 00:02:51.680
The government says Means altered QuickBooks entries so transfers into her personal accounts appeared to be standard business expenses, including supplies or invoices.
00:02:51.919 --> 00:02:57.360
She also used a separate bank account the business had not approved to divert company funds.
00:02:57.680 --> 00:03:00.080
There was another route, compensation.
00:03:00.400 --> 00:03:06.400
Means issued herself unauthorized payments, including duplicate salary payments and bonuses she had not earned.
00:03:06.639 --> 00:03:09.840
Consider what that looks like if you're reviewing the business from a distance.
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Supplies cost more than expected.
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An invoice gets paid.
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Payroll increases.
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Each has a possible explanation.
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Hospitality expenses move around.
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Staffing needs change.
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The question is whether anyone independently checked the explanation.
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Who was the supplier?
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What was delivered?
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Who approved the bonus?
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Why was there another salary payment?
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Who opened the separate account and why did company money enter it?
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The government's account says means control payroll, bank accounts, and tax reporting.
00:03:42.159 --> 00:03:46.560
That combination let the payments and their descriptions travel through the same hands.
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The remote arrangement let her keep managing those transactions electronically from Hawaii.
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The government charged wire fraud because the fraudulent transfers moved through interstate electronic communications.
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Then came the tax side.
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A person who takes money from an employer has received money, whatever the employer's books call the payment.
00:04:05.360 --> 00:04:10.000
The government says Means concealed the stolen income and filed false tax returns.
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Her federal guilty plea included one count of filing a false return.
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So there were two accounts of the same money.
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The business records called it an expense or compensation.
00:04:20.000 --> 00:04:23.360
Means tax reporting did not tell the full story of what she received.
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This is how an embezzlement case acquired its tax charge.
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So where was the criminal line?
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Start with the business.
00:04:31.759 --> 00:04:34.399
A mistaken expense category can be fixed.
00:04:34.639 --> 00:04:37.680
An accidental duplicate paycheck can be reversed.
00:04:37.920 --> 00:04:49.120
The conduct described here was a years-long series of unauthorized transfers, altered accounting entries, an unapproved account, duplicate pay, and unearned bonuses.
00:04:49.680 --> 00:04:52.639
For the tax case, the line was the false return.
00:04:52.879 --> 00:04:58.879
The government says means received money she had taken from the business, concealed that income, and filed false returns.
00:04:59.120 --> 00:05:03.839
A signed return matters because it's the taxpayer statement to the IRS about the year.
00:05:04.079 --> 00:05:14.000
Section 7206, Subsection 1 addresses willfully making a return under penalties of perjury that the signer does not believe is true as to a material matter.
00:05:14.160 --> 00:05:16.000
The theft created one victim.
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The false return created another.
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Here is what makes this an investigative story.
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The money had to move through records.
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The government identifies four parts of the trail: the accounting entries, transfers into means own accounts, the separate unauthorized bank account, and payments to herself through payroll.
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Put those pieces next to one another.
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An entry says supplies.
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The transfer went to an account means controlled.
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A payment says salary.
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The payroll history shows another salary payment.
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A bonus appears.
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Where's the approval?
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You do not need a dramatic confession to understand why those comparisons matter.
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And yet there is a limit to what I can say about this investigation.
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Court documents identifies the conduct and the records involved.
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It does not identify the first transaction someone questioned, say precisely how investigators discovered the separate account, or name a single entry as the decisive exhibit.
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I'm not going to invent that moment.
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What the court records do show is enough to explain the case.
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Descriptions in the books were compared with the actual movement of company money, and the government said those descriptions concealed payments to the bookkeeper.
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Then the tax question follows the money one step farther.
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What reach means?
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What did she report?
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The government says the stolen receipts were concealed and her returns were false.
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IRS criminal investigation, the FBI, and the Teton County Sheriff's Office investigated.
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That mix makes sense.
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The records concern both the business theft and tax reporting.
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The recurring document in this story is the accounting entry.
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A line labeled invoice seems dull.
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That is precisely why it deserves attention.
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The label tells the owner what the bookkeeper says happened.
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The bank transfer tells the owner where the money actually went.
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The government says means used expense labels for unauthorized transfers to her personal accounts.
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An owner reviewing only the expense category gets half the answer.
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The other half is the receiving account.
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The tax rule behind this case is simple.
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Illegal gains can be taxable income.
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Section 61 defines gross income broadly.
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Treasury Regulation Section 1.61-14A specifically says illegal gains constitute gross income.
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The employer might call a transfer of supplies.
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The recipient might wish it had been ordinary pay.
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The tax question still begins with what the person actually received.
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In Mean's case, the government says she can still stolen income and filed false returns.
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The court ordered more than$355,000 in restitution for these actions to the IRS.
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The practical takeaway: when the books in the bank disagree, follow the bank.
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There's another bookkeeper case that makes one point especially well.
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In United States vs.
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Penguin, an office manager used QuickBooks to send herself extra payments.
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Later, she marked those transactions as void.
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The payments remained in the transaction history, and an accountant reviewing the records identified them.
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That was a separate wire fraud case.
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I'm using it for one narrow comparison.
00:08:15.759 --> 00:08:18.800
Changing an accounting label does not undo a bank payment.
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Means reported method used different labels.
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The principle for anyone reviewing a business is the same.
00:08:24.879 --> 00:08:28.240
Look past the category and see where the funds landed.
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At this point, there were two paths for Means.
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If she was entitled to a raise, a bonus, or reimbursement, there was a straightforward way to get it.
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Request approval, document the payment, put it through the proper account, and report it correctly.
00:08:42.720 --> 00:08:52.320
If money had already been taken without approval, the next step was to stop, preserve the records, and get privileged advice before creating another explanation or filing another return.
00:08:52.480 --> 00:09:02.799
Instead, the government describes a pattern that continued for years: disguised transfers, an unauthorized account, duplicate salaries, unearned bonuses, and false returns.
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The longer that pattern continued, the more records there were to compare.
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I want to look at this from both sides of the desk because the person hearing this episode may be a business owner who trusts a bookkeeper or a tax professional reviewing a client's books.
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If the owners had come to me with unexplained payments, I would begin by preserving the accounting and bank records.
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Then I would ask for a transaction level reconciliation.
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Show me each payment label supplies or invoices.
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Show me the underlying invoice.
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Show me the person who approved it.
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Show me the destination account.
00:09:34.480 --> 00:09:38.399
And then do the same for bonuses, payroll adjustments, and reimbursements.
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I would also identify every business bank account and every authorized signer.
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In this case, the government says means use an account the business had not approved.
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An owner cannot meaningfully review cash if the list of company accounts itself is incomplete.
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Next, I would change the process.
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The person who enters a payment should not be its only approver and its only reviewer.
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An owner or independent person should review changes to pays, new bank accounts, bonuses, and unusual transfers against bank statements the reviewer obtains independently.
00:10:10.000 --> 00:10:11.679
That is an operational control.
00:10:11.919 --> 00:10:13.440
It's also a tax control.
00:10:13.919 --> 00:10:20.399
A business should absolutely know whether the expense entry is flowing into its tax work describe expenses it actually incurred.
00:10:20.559 --> 00:10:27.200
If prior business filings use incorrect records, the owners would need to determine which filings were affected and correct them as appropriate.
00:10:27.440 --> 00:10:33.200
I would not assume that means personal false return charge tells us what appeared on every return filed by that business.
00:10:33.360 --> 00:10:35.360
That is a separate records review.
00:10:35.600 --> 00:10:39.360
For a tax preparer or CPA, I would focus on contradictions.
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If a client's general ledger says supplies, but the bank record shows a transfer to an employee, ask what happened.
00:10:45.840 --> 00:10:50.879
There may be an authorized reimbursement, there may be an error, there may be something more serious.
00:10:51.120 --> 00:10:54.000
The answer needs support before it goes into a return.
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Now consider mean side.
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If a person had taken company funds, the issue goes well beyond preparing a corrected return.
00:11:01.039 --> 00:11:08.320
Counsel needs to evaluate the underlying conduct, the tax years, the records, and communications with the employer and government together.
00:11:08.480 --> 00:11:14.720
While I do civil tax resolution work, a case like this involving theft also requires criminal defense coordination.
00:11:14.960 --> 00:11:16.960
There's a distinction worth making here.
00:11:17.200 --> 00:11:26.960
The IRS has a voluntary disclosure practice for certain willful tax noncompliance, but its guidance says the practice does not apply to taxpayers with a legal source income.
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It would be wrong to promise someone in Means position that this procedure offers a clean route out of prosecution.
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My advice at the earliest point would be direct: stop the unauthorized payments, preserve what happened, and get advice before adding a false record to an already serious problem.
00:11:44.639 --> 00:11:49.759
Means had the access a hospitality business gave its bookkeeper so the business could operate.
00:11:49.919 --> 00:11:58.879
The government says she used that access to divert nearly$1.5 million, disguise transfers in the books, and conceal the stolen income on tax returns.
00:11:59.039 --> 00:12:04.639
She received a 46-month prison sentence and restitution orders to both the business and the IRS.
00:12:04.879 --> 00:12:06.000
Here is the lesson.
00:12:06.240 --> 00:12:09.200
An expense description tells you what someone called a payment.
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It does not tell you who got the money.
00:12:11.360 --> 00:12:13.360
I'm Jason Carr, tax attorney.
00:12:13.519 --> 00:12:16.960
If you want to make sure you never end up on this podcast, you know where to find me.
00:12:17.200 --> 00:12:18.559
Cartaxlaw.com.
00:12:18.720 --> 00:12:20.080
Link is in the show notes.
00:12:20.240 --> 00:12:24.000
This has been Final Notice, Real Text Cases Exposed.
00:12:25.039 --> 00:12:29.919
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00:12:36.559 --> 00:12:40.559
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00:12:40.639 --> 00:12:43.679
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