Promoter of Abusive Tax Shelter Indicted for Tax Crimes and for Retaliating Against Federal Officials

An indictment was unsealed on Monday in the Eastern District of Texas charging a Texas man with various tax crimes related to the use, promotion, and sale of an abusive tax shelter. He was also charged with filing false retaliatory liens against federal officials.

According to the indictment, Roger Napoleon Grant of Plano, Texas, used an abusive trust tax shelter to conceal his income from the IRS. He also allegedly promoted and sold this tax shelter to others. The tax shelter allegedly consisted of a multi-tiered trust structure typically consisting of at least two sham trusts and a purported charitable foundation. Grant allegedly told his clients that by implementing this structure, any income assigned to the trusts would be tax free. The indictment alleges that Grant typically charged clients between $12,500 to $50,000 to purchase the abusive trust tax shelter from him.

For the years 2017 through 2022, Grant allegedly assigned income he earned from promoting this tax shelter to a purported business trust. Though Grant reported about $80,521 in total income between 2017 and 2022, he received millions into a bank account held in the name of the purported business trust during that period. Grant had exclusive authority over this account, which he routinely used to pay for his personal expenses.

Grant was allegedly responsible for preparing and distributing the purported trust and foundation instruments for clients and providing clients with information and ongoing support related to their use of the tax shelter. Grant allegedly assured his clients that despite this reassignment of income, the clients' business operations would not change and that his clients, as trustees, would retain complete control over their businesses and the income that their businesses generated.

Grant allegedly knew that the deductions reported on both his and his client's trust tax returns were fraudulent and used to conceal his and his clients' true income from the IRS.

In April 2025, Grant learned about the criminal investigation against him. According to the indictment, Grant retaliated by filing false liens against government officials, including the Attorney General of the United States, the Acting IRS Commissioner, the Acting United States Attorney for the District of Colorado, the Clerk of Court for the District of Colorado, and an attorney with the Justice Department's Civil Division.

Grant is charged with five counts of tax evasion, 10 counts of aiding and assisting the filing of false income tax returns, and 10 counts of filing false retaliatory liens. If convicted, he faces a maximum penalty of five years in prison for each tax evasion count, three years in prison for each count of aiding and assisting in the filing of false income tax returns, and 10 years in prison for each count of filing false retaliatory liens.

Assistant Attorney General Colin McDonald of the Justice Department's National Fraud Enforcement Division and U.S. Attorney Jay R. Combs of the Eastern District of Texas made the announcement.

IRS Criminal Investigation is investigating the case.

Acting Assistant Deputy Chief Boris Bourget and Trial Attorney Lauren K. Pope of the Criminal Division's Tax Section are prosecuting the case.

An indictment is merely an allegation. All defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.

On April 7, the Department of Justice announced the creation of the National Fraud Enforcement Division (Fraud Division). The Fraud Division is laser-focused on investigating and prosecuting those who commit fraud against the American people. The Department's work to combat fraud supports President Trump's Task Force to Eliminate Fraud, a whole-of-government effort chaired by Vice President J.D. Vance to eliminate fraud, waste, and abuse within Federal benefit programs.