Evidence Record
Exhibit 14
02416654027 Received: 04/30/2024 Document 41-14 Filed 08/04/25
DISTIL analysis
DISTIL Run
Profile
Standard
Version
1
Doc Type
Notice of Federal Tax Lien (Form 668(Y)(c))
Total Nodes
22
Node Legend
Entity (ENT)
Event (EVT)
Claim (CLM)
Anchor (ANC)
Omission (OMI)
Tension (TEN)
Tell (TEL)
Inference (INF)
Hypothesis (HYP)
Stage 1
Index
Orientation · No nodes
Document Classification
Notice of Federal Tax Lien (Form 668(Y)(c)) Internal Revenue Service, Department of the Treasury Federal tax enforcement, corporate tax liability 2010-2024 (tax periods and filing)
legal_filingfinancial_encumbrancemulti_year_liability
Analytical Frame
Government enforcement action establishing lien priority
Analytical Summary
This IRS Notice of Federal Tax Lien documents a total unpaid tax liability of $559,716.86 against Cyberlux Corporation for multiple tax periods spanning 2010-2023. The lien was filed with the North Carolina Secretary of State on April 30, 2024, establishing federal claim priority on all corporate property and rights. The largest component is $334,730.87 for Form 941 (quarterly employment taxes) ending December 31, 2012. The notice includes four separate 941 assessments and one 940 assessment, with refiling deadlines extending through 2034. This represents a significant multi-year tax compliance failure creating substantial encumbrance on corporate assets.
Key Points
- Total unpaid tax liability of $559,716.86 assessed against Cyberlux Corporation
- Lien filed April 30, 2024 with North Carolina Secretary of State (File Number: 20240051953B)
- Five separate tax assessments: four Form 941 (employment tax) periods and one Form 940 (unemployment tax) period
- Largest liability is $334,730.87 for Q4 2012 employment taxes
- Lien covers all property and rights to property belonging to the corporation
- Tax periods span from 2010 to 2023, indicating extended compliance issues
Stage 2
Core — Entities, Events, Claims
13 nodes
ENT-001
Entity
Cyberlux Corporation
Cyberlux Corporation, a corporation with registered address at 800 Park Offices Drive Suite 3209, Durham, NC 27709-0000, is the taxpayer subject to this federal tax lien.
Page 2 — Name of Taxpayer CYBERLUX CORPORATION, a Corporation
Residence
800 PARK OFFICES DRIVE SUITE 3209
DURHAM, NC 27709-0000
ENT-002
Entity
Internal Revenue Service
Internal Revenue Service, Department of the Treasury, Small Business/Self Employed Area #3, Baltimore, MD office, is the government agency asserting the tax lien.
Page 2 — Department of the Treasury - Internal Revenue Service
Area:
SMALL BUSINESS/SELF EMPLOYED AREA #3
Lien Unit Phone: (800) 913-6050
This notice was prepared and signed at
BALTIMORE, MD
ENT-003
Entity
North Carolina Secretary of State
North Carolina Secretary of State, Elaine F. Marshall, is the recording office where the federal tax lien was filed.
Page 2 — For Optional Use by Recording Office
File Number: 20240051953B
Date Filed: 4/30/2024 10:00:00 AM
Elaine F. Marshall
NC Secretary of State
Place of Filing.
SECRETARY OF STATE
NORTH CAROLINA
RALEIGH, NC 27626-0622
EVT-001
Event
Tax Lien Filing - April 30, 2024
The IRS filed Notice of Federal Tax Lien with the North Carolina Secretary of State on April 30, 2024 at 10:00:00 AM, assigned file number 20240051953B.
Page 2 — For Optional Use by Recording Office
File Number: 20240051953B
Date Filed: 4/30/2024 10:00:00 AM
Elaine F. Marshall
NC Secretary of State
EVT-002
Event
Tax Assessment - Form 941 Q4 2012
The IRS assessed Form 941 (employment tax) liability of $334,730.87 for the tax period ending December 31, 2012, with assessment date of April 1, 2013.
Page 2 — 941
12/31/2012
04/01/2013
05/01/2033
334730.87
EVT-003
Event
Tax Assessment - Form 941 Q4 2010 (Initial)
The IRS made an initial assessment for Form 941 (employment tax) liability for the tax period ending December 31, 2010, with assessment date of April 11, 2011.
Page 2 — 941
12/31/2010
Privacy
04/11/2011
05/11/2031
EVT-004
Event
Tax Assessment - Form 941 Q4 2010 (Reassessment)
The IRS made a subsequent assessment for Form 941 liability of $178,708.29 for the same tax period ending December 31, 2010, with assessment date of September 10, 2012.
Page 2 — 941
12/31/2010
Redaction
09/10/2012
10/10/2032
178708.29
EVT-005
Event
Tax Assessment - Form 941 Q2 2010
The IRS assessed Form 941 liability of $46,023.00 for the tax period ending June 30, 2010, with assessment date of May 13, 2013.
Page 2 — 941
06/30/2010
05/13/2013
06/12/2033
46023.00
EVT-006
Event
Tax Assessment - Form 940 2023
The IRS assessed Form 940 (unemployment tax) liability of $254.70 for the tax period ending December 31, 2023, with assessment date of February 26, 2024.
Page 2 — 940
12/31/2023
02/26/2024
03/28/2034
254.70
EVT-007
Event
Notice Preparation and Signing
The notice was prepared and signed at Baltimore, MD on April 16, 2024 by Elvin Dean Cury, Acting Manager for T McCrimmon.
Page 2 — This notice was prepared and signed at
BALTIMORE, MD
, on this,
the
16th
day of
April
2024
,
.
Signature
Elvin Dean Cury
Title
ACTING MANAGER
23-06-4407
for T MCCRIMMON
CLM-001
Claim
Total Tax Liability Amount
The total unpaid balance of assessment against Cyberlux Corporation is $559,716.86.
Page 2 — Total
$
559716.86
CLM-002
Claim
Legal Basis for Lien
The IRS asserts that under sections 6321, 6322, and 6323 of the Internal Revenue Code, taxes have been assessed, demand for payment made but remains unpaid, creating a lien in favor of the United States on all property and rights to property belonging to the taxpayer.
Page 2 — As provided by section 6321, 6322, and 6323 of the Internal Revenue
Code, we are giving a notice that taxes (including interest and penalties)
have been assessed against the following-named taxpayer. We have made
a demand for payment of this liability, but it remains unpaid. Therefore,
there is a lien in favor of the United States on all property and rights to
property belonging to this taxpayer for the amount of these taxes, and
additional penalties, interest, and costs that may accrue.
CLM-003
Claim
Scope of Lien Encumbrance
The lien covers all property and rights to property belonging to Cyberlux Corporation for the amount of taxes, and additional penalties, interest, and costs that may accrue.
Page 2 — there is a lien in favor of the United States on all property and rights to
property belonging to this taxpayer for the amount of these taxes, and
additional penalties, interest, and costs that may accrue.
Stage 3
In Situ — Quotations, Tells, Tensions, Questions
4 nodes
TEN-001
Tension
Dual Assessment for Q4 2010
Two separate assessments exist for the same tax period ending December 31, 2010: one assessed on April 11, 2011 (amount redacted under 'Privacy') and another assessed on September 10, 2012 for $178,708.29 (marked 'Redaction'). This dual assessment pattern suggests either reassessment, additional penalties, or correction of initial filing.
Page 2 — 941
12/31/2010
Privacy
04/11/2011
05/11/2031
941
12/31/2010
Redaction
09/10/2012
10/10/2032
178708.29
TEN-002
Tension
13-Year Gap in Tax Periods
The assessed tax periods show a significant temporal gap: liabilities exist for 2010, 2012, and 2023, but no assessments are listed for the intervening years (2011, 2013-2022). This pattern raises questions about whether the company had no tax obligations, filed compliant returns, or whether other liens exist separately.
Page 2 — 940
12/31/2023
02/26/2024
03/28/2034
254.70
941
06/30/2010
05/13/2013
06/12/2033
46023.00
941
12/31/2010
Privacy
04/11/2011
05/11/2031
941
12/31/2010
Redaction
09/10/2012
10/10/2032
178708.29
941
12/31/2012
04/01/2013
05/01/2033
334730.87
QST-001
Question
Redacted Amount for Initial Q4 2010 Assessment
What is the unpaid balance amount for the first Form 941 assessment for the period ending December 31, 2010, assessed on April 11, 2011? The amount is marked 'Privacy' and redacted from the document.
Page 2 — 941
12/31/2010
Privacy
04/11/2011
05/11/2031
QST-002
Question
Corporate Operational Status During Gap Years
Was Cyberlux Corporation operationally active and employing workers during the years 2013-2022? If so, were employment tax returns filed and paid for those years, or do separate liens or assessments exist that are not reflected in this filing?
Page 2 — 940
12/31/2023
02/26/2024
03/28/2034
254.70
941
12/31/2012
04/01/2013
05/01/2033
334730.87
Stage 4
Interpretive — Inferences, Omissions, Patterns
5 nodes
INF-001
Inference
Pattern of Employment Tax Non-Compliance
The concentration of four Form 941 (employment tax) assessments out of five total assessments, with the largest single liability being $334,730.87 for Q4 2012, suggests systematic failure to withhold and/or remit employee payroll taxes during periods when the company was actively employing personnel.
Page 2 — 941
06/30/2010
05/13/2013
06/12/2033
46023.00
941
12/31/2010
Privacy
04/11/2011
05/11/2031
941
12/31/2010
Redaction
09/10/2012
10/10/2032
178708.29
941
12/31/2012
04/01/2013
05/01/2033
334730.87
INF-002
Inference
Multi-Year Collection Efforts
The assessment dates ranging from 2011 to 2024, with the lien not filed until April 2024, suggest the IRS has been attempting collection through other means for over a decade before escalating to the lien filing stage. The 2013 assessments for 2010 tax periods indicate prior collection or examination activity that was unsuccessful.
Page 2 — 941
06/30/2010
05/13/2013
06/12/2033
46023.00
941
12/31/2010
Privacy
04/11/2011
05/11/2031
941
12/31/2010
Redaction
09/10/2012
10/10/2032
178708.29
Date Filed: 4/30/2024 10:00:00 AM
INF-003
Inference
Potential Recent Operational Changes
The relatively small Form 940 assessment of $254.70 for 2023, compared to the large 2010-2012 employment tax liabilities, may indicate either minimal employment activity in 2023, downsizing, or improved but incomplete tax compliance. This is the only recent tax period showing assessment activity.
Page 2 — 940
12/31/2023
02/26/2024
03/28/2034
254.70
941
12/31/2012
04/01/2013
05/01/2033
334730.87
OMI-001
Omission
No Information on Payment Demand History
The notice states that demand for payment has been made but remains unpaid, but provides no details about when demand was made, how many demands were issued, what communication methods were used, or whether any partial payments were attempted or accepted.
Page 2 — We have made
a demand for payment of this liability, but it remains unpaid.
OMI-002
Omission
No Breakdown of Principal, Interest, and Penalties
The unpaid balance amounts listed represent totals including principal tax, penalties, and accrued interest, but the document provides no breakdown showing how much of each liability consists of original tax versus accumulated penalties and interest over 10+ years.
Page 2 — taxes (including interest and penalties)
have been assessed against the following-named taxpayer
Total
$
559716.86
Extracted text
2 pages · 2325 charactersEXHIBIT 14
02416654027
Received: 04/30/2024 Document 41-14 Filed 08/04/25
Page 2 of 2 PageID# 635
Form 668 (Y)(c) (Rev. February 2004)
Department of the Treasury - Internal Revenue Service
Notice of Federal Tax Lien
Area:
SMALL BUSINESS/SELF EMPLOYED AREA #3
Lien Unit Phone: (800) 913-6050
Serial Number 491794824
As provided by section 6321, 6322, and 6323 of the Internal Revenue Code, we are giving a notice that taxes (including interest and penalties) have been assessed against the following-named taxpayer. We have made a demand for payment of this liability, but it remains unpaid. Therefore, there is a lien in favor of the United States on all property and rights to property belonging to this taxpayer for the amount of these taxes, and additional penalties, interest, and costs that may accrue.
For Optional Use by Recording Office
File Number: 20240051953B Date Filed: 4/30/2024 10:00:00 AM Elaine F. Marshall NC Secretary of State
Name of Taxpayer CYBERLUX CORPORATION, a Corporation
Residence
800
PARK OFFICES DRIVE SUITE 3209
DURHAM, NC 27709-0000
IMPORTANT RELEASE INFORMATION: For each assessment listed below, unless notice of the lien is refiled by the date given in column (e), this notice shall, on the day following such date, operate as a certificate of release as defined in IRC 6325(a).
Kind of Tax (a)
Tax Period Ending (b)
Identifying Number (c)
Date of Assessment (d)
Last Day for Refiling (e)
Unpaid Balance of Assessment (f)
12/31/2023
02/26/2024
03/28/2034
254.70
06/30/2010
05/13/2013
06/12/2033
46023.00
12/31/2010
Privacy
04/11/2011
05/11/2031
12/31/2010
Redaction
09/10/2012
10/10/2032
12/31/2012
04/01/2013
05/01/2033
Place of Filing. SECRETARY OF STATE NORTH CAROLINA RALEIGH, NC 27626-0622
Total
$ 559716.86
This notice was prepared and signed at BALTIMORE, MD , on this, the 16th day of April 2024 , .
Signature Elvin Dean Cury
Title ACTING MANAGER
23-06-4407
for T MCCRIMMON
(919)
850-1189
(NOTE: Certificate of officer authorized by law to take acknowledgment is not essential to the validity of Notice of Federal Tax lien Rev. Rul. 71-466, 1971 - 2 C.B. 409)
Part 1 - Kept By Recording Office
Form 668(Y)(c) (Rev. 2-2004) CAT. NO 60025X
Original source file
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- File
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- Source UID
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- Full SHA-256
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