AFFIDAVIT

I, Pete Dyer, offer the following information in support of a criminal complaint

charging O l u f u n s h o Ad e s h i n a with theft of government funds in violation of Title 18, United
States Code Section 641. The information contained herein is true and accurate to the best of
my knowledge and belief and has been collected through business records, official records,
witness accounts and otherwise. This information is, therefore, not necessarily known to me
firsthand but it is, in my training and experience as a law enforcement officer, reliable.
Affiant
I am a Special Agent with the Internal Revenue Service - Criminal Investigations
office and have been so employed for 3 years. During that time, I have worked on numerous
criminal tax investigations including as the lead investigative agent. These investigations
have included numerous Stolen Identity Refund Fraud [SIRF] cases like the one described
below. Before becoming a Special Agent, I attended the Federal Law Enforcement Training
Center for six months and received training on criminal investigative techniques and
practices. Additionally, I receive required continuing education as a federal law enforcement
agent.
SIRF cases have become prevalent over the last five years. Typically, identifiers of
taxpayers are stolen from various sources including public records, health care records and
otherwise and used to prepare false tax returns calling for a refund. The identity thief and
often others working with him direct these refunds to a physical address or to a financial
account they control. Before the identity theft victim is able to file his or her taxes, a refund is
paid out to the benefit of the identity thief.

The Defendant
Olufunsho Adeshina is a native of Nigeria and a permanent resident of the United States
residing in the City of St. Louis in the Eastern District of Missouri. Official records filed with the
Missouri Secretary of State for businesses established by Defendant as well as Defendants public
facebook social media account suggest Defendant is a musician working in the St. Louis area.
The Defendants Financial Accounts
I have identified 4 accounts in the names of business entities for which Defendant is the sole
signatory at Commerce Bank, a financial institution with branches in the Eastern District of
Missouri. Since January 1, 2015, approximately $52,000 in United States Treasury ACH tax refund
deposits have been directed to these accounts. Official records show that the tax returns filed to
generate these refunds were filed in the names of other individuals not associated with Defendant or
his business entities. One specific tax return filed using the identity of R.F. contained false Form
W-2 wages and false federal income tax withholdings that resulted in a $8,865 fraudulent tax refund
being deposited into one of the Defendants Commerce Bank accounts. The employer claimed on
the false Form W-2 confirmed the wages and withholdings are false.
I have identified 7 accounts in the Defendants name at Fifth Third Bank branches in the
Eastern District of Missouri. Fifth Third Bank is a financial institution. Since January 1, 2015,
approximately $61,000 in United States Treasury ACH tax refund deposits have been directed to
these accounts. Official records show that the tax returns filed to generate these refunds were filed
in the names of others individuals not associated with Defendant or his business entities.
I have identified 10 accounts in the Defendants name at US Bank branches in the Eastern
District of Missouri. US Bank is a financial institution. Since January 1, 2015, approximately
$75,000 in United States Treasury ACH tax refund deposits have been directed to these accounts.
Official records show that the tax returns filed to generate these refunds were filed in the names of
other individuals not associated with Defendant or his business entities.
2

2013 Tax Year Activity

For the tax year 2013, official records reveal that 23 tax returns for individuals were
filed with the IRS listing [ADDRESS REDACTED]. According to official records and a
public facebook social media account in Defendants name, [ADDRESS REDACTED] is
Defendants home address. These tax returns have been reviewed and found to include
false income items when compared to official records submitted to the IRS from third
parties such as employers forms W-2.
All of the refunds d e s c r i b e d i n t h i s a ffi d a v i t r e p r e s e n t moneys of the United
States.
Conclusion
In my training and experience, the foregoing evidence demonstrates probable cause to
believe that the defendant has submitted or caused to be submitted false and fraudulent tax returns
filed in the names of other individuals which refunds represent funds of the United States in violation
of Title 18, United States Code Section 641, and respectfully request the Court issue a criminal
complaint charging O l u f u n s h o A d e s h i n a with the same.