Case 3:22-cr-00345-TLT Document 1 Filed 09/09/22 Page 1 of 4

FILED
1 STEPHANIE M. HINDS (CABN 154284)
United States Attorney
2 Sep 09 2022

3 Mark B. Busby
CLERK, U.S. DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
5 SAN FRANCISCO
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8 UNITED STATES DISTRICT COURT

9 NORTHERN DISTRICT OF CALIFORNIA

10 SAN FRANCISCO DIVISION

11 UNITED STATES OF AMERICA, ) CR22-345 TLT

)
12 Plaintiff, ) VIOLATIONS:
) 26 U.S.C. § 7201 – Tax Evasion (5 counts)
13 v. )
)
14 RODRIGO SANTOS, ) SAN FRANCISCO VENUE
)
15 Defendant. )
)
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17 INFORMATION
18 The United States Attorney charges:
19 COUNT ONE: (26 U.S.C. § 7201 – Tax Evasion)
20 During the calendar year 2015, in the Northern District of California, and elsewhere, the
21 defendant,

22 RODRIGO SANTOS,
23 a resident of San Francisco, California, willfully attempted to evade and defeat income tax due and

24 owing by him to the United States of America, for the calendar year 2015, by preparing and causing to

25 be prepared, and by signing and causing to be signed, a false and fraudulent U.S. Individual Income Tax

26 Return, Form 1040, which was submitted to the Internal Revenue Service. On that tax return, the
27 defendant reported and caused to be reported that his and his spouse’s joint taxable income for the

28 calendar year 2015 was $79,991.00 and that the amount of tax due and owing was $11,505.00. In fact,

INFORMATION
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 Case 3:22-cr-00345-TLT Document 1 Filed 09/09/22 Page 2 of 4

1 as the defendant knew, his and his spouse’s joint taxable income for the calendar year 2015 was greater

2 than the amount reported on the tax return, and because of such additional taxable income, there was

3 substantial additional tax due and owing to the United States of America.

4 All in violation of Title 26, United States Code, Section 7201.

5 COUNT TWO: (26 U.S.C. § 7201 – Tax Evasion)

6 During the calendar year 2016, in the Northern District of California, and elsewhere, the

7 defendant,

8 RODRIGO SANTOS,

9 a resident of San Francisco, California, willfully attempted to evade and defeat income tax due and

10 owing by him to the United States of America, for the calendar year 2016, by preparing and causing to

11 be prepared, and by signing and causing to be signed, a false and fraudulent U.S. Individual Income Tax

12 Return, Form 1040, which was submitted to the Internal Revenue Service. On that tax return, the

13 defendant reported and caused to be reported that his and his spouse’s joint taxable income for the

14 calendar year 2016 was $152,947.00 and that the amount of tax due and owing was $33,546.00. In fact,

15 as the defendant knew, his and his spouse’s joint taxable income for the calendar year 2016 was greater

16 than the amount reported on the tax return, and because of such additional taxable income, there was

17 substantial additional tax due and owing to the United States of America.

18 All in violation of Title 26, United States Code, Section 7201.

19 COUNT THREE: (26 U.S.C. § 7201 – Tax Evasion)

20 During the calendar year 2017, in the Northern District of California, and elsewhere, the

21 defendant,

22 RODRIGO SANTOS,

23 a resident of San Francisco, California, willfully attempted to evade and defeat income tax due and

24 owing by him to the United States of America, for the calendar year 2017, by preparing and causing to

25 be prepared, and by signing and causing to be signed, a false and fraudulent U.S. Individual Income Tax

26 Return, Form 1040, which was submitted to the Internal Revenue Service. On that tax return, the
27 defendant reported and caused to be reported that his and his spouse’s joint taxable income for the

28 calendar year 2017 was $178,404.00 and that the amount of tax due and owing was $40,842.00. In fact,

INFORMATION 2
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 Case 3:22-cr-00345-TLT Document 1 Filed 09/09/22 Page 3 of 4

1 as the defendant knew, his and his spouse’s joint taxable income for the calendar year 2017 was greater

2 than the amount reported on the tax return, and because of such additional taxable income, there was

3 substantial additional tax due and owing to the United States of America.

4 All in violation of Title 26, United States Code, Section 7201.

5 COUNT FOUR: (26 U.S.C. § 7201 – Tax Evasion)

6 During the calendar year 2018, in the Northern District of California, and elsewhere, the

7 defendant,

8 RODRIGO SANTOS,

9 a resident of San Francisco, California, willfully attempted to evade and defeat income tax due and

10 owing by him to the United States of America, for the calendar year 2018, by preparing and causing to

11 be prepared, and by signing and causing to be signed, a false and fraudulent U.S. Individual Income Tax

12 Return, Form 1040, which was submitted to the Internal Revenue Service. On that tax return, the

13 defendant reported and caused to be reported that his and his spouse’s joint taxable income for the

14 calendar year 2018 was $238,479.00 and that the amount of tax due and owing was $45,735.00. In fact,

15 as the defendant knew, his and his spouse’s joint taxable income for the calendar year 2018 was greater

16 than the amount reported on the tax return, and because of such additional taxable income, there was

17 substantial additional tax due and owing to the United States of America.

18 All in violation of Title 26, United States Code, Section 7201.

19 COUNT FIVE: (26 U.S.C. § 7201 – Tax Evasion)

20 During the calendar year 2019, in the Northern District of California, and elsewhere, the

21 defendant,

22 RODRIGO SANTOS,

23 a resident of San Francisco, California, willfully attempted to evade and defeat income tax due and

24 owing by him to the United States of America, for the calendar year 2019, by preparing and causing to

25 be prepared, and by signing and causing to be signed, a false and fraudulent U.S. Individual Income Tax

26 Return, Form 1040, which was submitted to the Internal Revenue Service. On that tax return, the
27 defendant reported and caused to be reported that his and his spouse’s joint taxable income for the

28 calendar year 2019 was $336,127.00 and that the amount of tax due and owing was $75,288.00. In fact,

INFORMATION 3
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1 as the defendant knew, his and his spouse’s joint taxable income for the calendar year 2019 was greater

2 than the amount reported on the tax return, and because of such additional taxable income, there was

3 substantial additional tax due and owing to the United States of America.

5 DATED: September 9, 2022 STEPHANIE M. HINDS

United States Attorney
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CASEY BOOME
8 Assistant United States Attorney
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