United States of America v. Charles Randall Sorensen

Minneapolis, Minnesota criminal defense lawyer represented the Defendant charged with tax evasion and fraud.



Sorensen, a successful pilot for 37 years, retired from Delta Air Lines in 2016

at the mandatory retirement age of 65. His history of tax evasion extends back to at

least 2010, when he and his then-wife accumulated tax debts because Sorensen

under-withheld contributions from his paychecks against the advice of their Certified

Public Accountant.



Relevant here, from at least 2016 to 2021, Sorensen engaged in a pattern of

conduct intended to evade the assessment, payment, and collection of federal income

taxes for years 2015 to 2019. He failed to file tax returns, filed false tax returns,

filed returns claiming refunds to which he was not entitled, hid income and assets,

and refused to cooperate with the IRS.



Facing IRS collection efforts, Sorensen concealed his sources of income and

sheltered assets. He created shell companies, including LAWTAM—a purportedly

religious and humanitarian nonprofit organization—and opened bank accounts in

the names of those shell companies. After the IRS subjected LAWTAM's business

accounts to levies, Sorensen transferred funds to LAMP—a sham educational

organization.



Eventually, Sorensen liquidated his investments and retirement accounts,

depositing the proceeds into a cryptocurrency exchange. The IRS could not impose

levies on the account because Sorensen transferred assets to a digital wallet.

Throughout, Sorensen filed frivolous documents and lawsuits, challenging the

authority of the IRS to assess and collect income taxes.

In sum, Sorensen became accountable for a tax loss of $370,471 relating to

individual taxes evaded in tax years 2015 to 2019, and an intended tax loss of

$1,491,251 relating to his false claim for a refund in tax year 2019. The aggregate

tax loss was $1,861,722.-3-

A jury convicted Sorensen of two counts of filing a false tax return, one count

of tax evasion, three counts of failing to file a tax return, and one count of making a

false claim against the United States. The district court sentenced him to 41 months

in prison. On appeal, Sorensen challenges the district court’s admission at trial of

testimony from various witnesses not qualified as experts, and its application of the

sophisticated means enhancement at sentencing.



Affirmed