The evidence/GT-S-C039A0519EC2

Context source · GT-S-C039A0519EC2

United States tax discovery — seven assessments and mixed balance dates

Original sourceRevenue Officer certified discovery response; asserted federal tax liens and amounts, not an adjudication of priority.
SHA-256 c039a0519ec2aea6c7c7…0 pages · 276 KB

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claimallegation

EDVA175-23 Exhibit21 filed April15,2026 preserves the United States discovery response. Revenue Officer Carol Davis signs under penalty of p

EDVA175-23 Exhibit21 filed April15,2026 preserves the United States discovery response. Revenue Officer Carol Davis signs under penalty of perjury dated March4,2026. Counsel response and email-service certificate are dated March5,2026, with the day handwritten; the certificate carries Elizabeth Pruitt’s ink signature. These dates precede the main stated March26 balance date.

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EXHIBIT 21 Case 3:25-cv-00483-JAG Document 175-23 Filed 04/15/26 Page 1 of 6 PageID# 2914
claimallegation

The United States claims $1,149,776.34 plus continuing interest and statutory additions. Seven rows sum exactly to that amount: Form941 June

The United States claims $1,149,776.34 plus continuing interest and statutory additions. Seven rows sum exactly to that amount: Form941 June2010 $87,188.95; Form941 December2010 $149,003.11; Form941 December2012 $869,532.75; Form941 December2021 $2,617.01; Form940 December2022 $320.48; Form940 December2023 $358.73; section6721 December2013 penalty $40,755.31.

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Case 3:25-cV-00483-JAG Document 175-23 Filed 04/15/26 Page 2 of 6 PagelD# 2915 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. Case No. 3:25-cv-00483-JAG Interpleader Plaintiff, CYBERLUX CORPORATION, et. al., Defendants. DEFENDANT UNITED STATES OF AMERICA'S RESPONSES TO DISCOVERY REQUESTS INTERROGATORIES Explain the nature of your claim to any of the proceeds that are the subject of this Interpleader, including an explanation of: A. The amount of the proceeds that you claim. Response: The United States claims proceeds in the amount of $1,149,776.34, as of March 26, 2026, plus interest and statutory additions that will continue to accrue according to law. B. The legal basis for your right to the proceeds. Response: The United States has a right to the proceeds pursuant to 26 U.S.C. § 6321 (Lien for Taxes), 26 U.S.C. § 6322 (Period of Lien), and 26 U.S.C. § 6323 (Priority & Validity). A delegate of the Secretary of the Treasury assessed taxes and penalties against Cyberlux Corporation for tax periods in 2010, 2012, 2013, 2021, 2022 and 2023. These assessments by the United States against Cyberlux Corporation are summarized in Table 1 below: 1
claimallegation

Table1 generally uses March26,2026 balances, but footnote1 expressly uses February16,2026 for the December2010 Form941 row. The displayed ag

Table1 generally uses March26,2026 balances, but footnote1 expressly uses February16,2026 for the December2010 Form941 row. The displayed aggregate therefore combines balance dates; it is not a uniformly dated payoff. Assessment dates respectively are May13,2013; April11,2011; April1,2013; September5,2022; February27,2023; February26,2024; October24,2016.

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Case 3:25-cv-00483-JAG Document 175-23 Filed 04/15/26 _ Page 3 of 6 PagelD# 2916 TABLE 1: ASSESSMENTS AGAINST CYBERLUX CORPORATION Tax Tpe Assessment NFTL Total Due (including Tax Period Date Filing Date interest & penalties) as of March 26, 2026 IRS Form 941 6/30/2010 5/13/2013 4/30/2024 $87,188.95 IRS Form 941 12/31/2010 4/11/2011 4/30/2024 $149,003.11 IRS Form 941 12/31/2012 4/01/2013 4/30/2024 $869,532.75 IRS Form 941 12/31/2021 9/5/2022 10/10/2023 $2,617.01 IRS Form 940 12/31/2022 2/27/2023 10/10/2023 $320.48 IRS Form 940 12/31/2023 2/26/2024 4/30/2024 $358.73 26 USC § 6721 12/31/2013 10/24/2016 8/21/2017 $40,755.31 Total: $1,149,776.34 A delegate of the Secretary of the Treasury gave notice of these assessments to Cyberlux Corporation and made demand upon it for payment of those assessments. Despite this notice and demand for payment, Cyberlux Corporation has failed or refused to pay the full amounts due and owing for these assessments. As a result, under 26 U.S.C. § 6321, the amounts of these unpaid taxes and penalties are a lien in favor of the United States upon all property and rights to property belonging to Cyberlux Corporation, including upon the interpleaded proceeds. Under 26 U.S.C. § 6322, that lien arose at the time the assessments were made. Under 26 U.S.C. § 6323, the liens are effective as to other creditors because of the filing of the Notices of Federal Tax Lien (NFTLs") with the North Carolina Secretary of State. The filing dates for the NFTLs are summarized in Table 1 above. Copies of those NFTLs were produced with the United States' Initial Disclosures. C. How the amount you claim became a liquidated amount or, if not liquidated, state so. Response: Cyberlux Corporation is indebted to the United States for unpaid Form 940 and Form 941 tax liabilities and for penalties assessed under 26 U.S.C. § 6721. The amounts the United States claims became liquidated amounts at the time the assessments were made. ' Unlike the other tax debts, which are calculated with interest accruing through March 26, 2026, this fourth quarter of 2010 Form 941 tax debt is calculated as of February 16, 2026. 2
claimallegation

NFTL filing dates are April30,2024 for the first three and December2023 rows; October10,2023 for December2021 and December2022; August21,201

NFTL filing dates are April30,2024 for the first three and December2023 rows; October10,2023 for December2021 and December2022; August21,2017 for the section6721 penalty. The response asserts notice, demand, unpaid assessments and liens on Cyberlux property including the proceeds. It distinguishes assessment-time lien creation from effectiveness against other creditors through filing, and says priority will be determined under section6323. This is the claimant’s position, not a supplied priority ruling.

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Case 3:25-cv-00483-JAG Document 175-23 Filed 04/15/26 _ Page 3 of 6 PagelD# 2916 TABLE 1: ASSESSMENTS AGAINST CYBERLUX CORPORATION Tax Tpe Assessment NFTL Total Due (including Tax Period Date Filing Date interest & penalties) as of March 26, 2026 IRS Form 941 6/30/2010 5/13/2013 4/30/2024 $87,188.95 IRS Form 941 12/31/2010 4/11/2011 4/30/2024 $149,003.11 IRS Form 941 12/31/2012 4/01/2013 4/30/2024 $869,532.75 IRS Form 941 12/31/2021 9/5/2022 10/10/2023 $2,617.01 IRS Form 940 12/31/2022 2/27/2023 10/10/2023 $320.48 IRS Form 940 12/31/2023 2/26/2024 4/30/2024 $358.73 26 USC § 6721 12/31/2013 10/24/2016 8/21/2017 $40,755.31 Total: $1,149,776.34 A delegate of the Secretary of the Treasury gave notice of these assessments to Cyberlux Corporation and made demand upon it for payment of those assessments. Despite this notice and demand for payment, Cyberlux Corporation has failed or refused to pay the full amounts due and owing for these assessments. As a result, under 26 U.S.C. § 6321, the amounts of these unpaid taxes and penalties are a lien in favor of the United States upon all property and rights to property belonging to Cyberlux Corporation, including upon the interpleaded proceeds. Under 26 U.S.C. § 6322, that lien arose at the time the assessments were made. Under 26 U.S.C. § 6323, the liens are effective as to other creditors because of the filing of the Notices of Federal Tax Lien (NFTLs") with the North Carolina Secretary of State. The filing dates for the NFTLs are summarized in Table 1 above. Copies of those NFTLs were produced with the United States' Initial Disclosures. C. How the amount you claim became a liquidated amount or, if not liquidated, state so. Response: Cyberlux Corporation is indebted to the United States for unpaid Form 940 and Form 941 tax liabilities and for penalties assessed under 26 U.S.C. § 6721. The amounts the United States claims became liquidated amounts at the time the assessments were made. ' Unlike the other tax debts, which are calculated with interest accruing through March 26, 2026, this fourth quarter of 2010 Form 941 tax debt is calculated as of February 16, 2026. 2
claimallegation

The United States expressly claims no attorneys’ fees and states it did not advance money to Cyberlux. The claim described here is unpaid ta

The United States expressly claims no attorneys’ fees and states it did not advance money to Cyberlux. The claim described here is unpaid tax and penalty liability, with continuing statutory interest, rather than a loan or procurement-loss demand.

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Case 3:25-cv-00483-JAG Document 175-23 Filed 04/15/26 Page 4 of 6 PagelD# 2917 D. Whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment. Response: The United States claims liens on all property and rights to property of Cyberlux Corporation, including a portion of the proceeds. The United States' liens became effective as to other creditors upon the filing of the NFTLs referred to above. The priority of the United States' liens will be determined by application of 26 U.S.C. § 6323. E. Whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any. Response: The United States claims a right to interest pursuant to 26 U.S.C. §§ 6601(a) and 6621(a)(2). The United States seeks $1,149,776.34, as of March 26, 2026, plus interest and statutory additions that will continue to accrue according to statutory law. F. Whether you claim a right to attorneys' fees. Response: N/A. The United States does not claim a right to attorneys' fees. G. For any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed. Response: N/A. The United States did not advance money to Cyberlux. CERTIFICATION I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Carol Dans Dated: March 4, 2026 CAROL DAVIS Revenue Officer Internal Revenue Service
claimallegation

Both production responses state supporting documents were produced February19,2026 as USA0001–15. Those fifteen Bates pages are not attached

Both production responses state supporting documents were produced February19,2026 as USA0001–15. Those fifteen Bates pages are not attached to this six-page exhibit. Production assertion does not itself permit examination of the assessments or notices.

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Case 3:25-cv-00483-JAG Document 175-23 Filed 04/15/26 Page 5 of 6 PagelD# 2918 DOCUMENT REQUESTS Documents supporting or otherwise concerning your answer to the above interrogatory. Response: The responsive documents were produced on February 19, 2026, and are bates- stamped USA0001-15. All documents on which you rely to assert any security interest in, lien on, or assignment of the proceeds that are the subject of this interpleader. Response: The responsive documents were produced on February 19, 2026, and are bates- stamped USA0001-15. 4
entityobservation

UNITED STATES OF AMERICA

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Case 3:25-cV-00483-JAG Document 175-23 Filed 04/15/26 Page 2 of 6 PagelD# 2915 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. Case No. 3:25-cv-00483-JAG Interpleader Plaintiff, CYBERLUX CORPORATION, et. al., Defendants. DEFENDANT UNITED STATES OF AMERICA'S RESPONSES TO DISCOVERY REQUESTS INTERROGATORIES Explain the nature of your claim to any of the proceeds that are the subject of this Interpleader, including an explanation of: A. The amount of the proceeds that you claim. Response: The United States claims proceeds in the amount of $1,149,776.34, as of March 26, 2026, plus interest and statutory additions that will continue to accrue according to law. B. The legal basis for your right to the proceeds. Response: The United States has a right to the proceeds pursuant to 26 U.S.C. § 6321 (Lien for Taxes), 26 U.S.C. § 6322 (Period of Lien), and 26 U.S.C. § 6323 (Priority & Validity). A delegate of the Secretary of the Treasury assessed taxes and penalties against Cyberlux Corporation for tax periods in 2010, 2012, 2013, 2021, 2022 and 2023. These assessments by the United States against Cyberlux Corporation are summarized in Table 1 below: 1
entityobservation

CYBERLUX CORPORATION

Read the anchor · page 2
Case 3:25-cV-00483-JAG Document 175-23 Filed 04/15/26 Page 2 of 6 PagelD# 2915 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division HII MISSION TECHNOLOGIES CORP. Case No. 3:25-cv-00483-JAG Interpleader Plaintiff, CYBERLUX CORPORATION, et. al., Defendants. DEFENDANT UNITED STATES OF AMERICA'S RESPONSES TO DISCOVERY REQUESTS INTERROGATORIES Explain the nature of your claim to any of the proceeds that are the subject of this Interpleader, including an explanation of: A. The amount of the proceeds that you claim. Response: The United States claims proceeds in the amount of $1,149,776.34, as of March 26, 2026, plus interest and statutory additions that will continue to accrue according to law. B. The legal basis for your right to the proceeds. Response: The United States has a right to the proceeds pursuant to 26 U.S.C. § 6321 (Lien for Taxes), 26 U.S.C. § 6322 (Period of Lien), and 26 U.S.C. § 6323 (Priority & Validity). A delegate of the Secretary of the Treasury assessed taxes and penalties against Cyberlux Corporation for tax periods in 2010, 2012, 2013, 2021, 2022 and 2023. These assessments by the United States against Cyberlux Corporation are summarized in Table 1 below: 1
entityobservation

CAROL DAVIS

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Case 3:25-cv-00483-JAG Document 175-23 Filed 04/15/26 Page 4 of 6 PagelD# 2917 D. Whether you claim a security interest in, lien on, or assignment of all or any portion of the proceeds and, if so, provide your claimed priority date and explain the basis for your security interest, lien, or assignment. Response: The United States claims liens on all property and rights to property of Cyberlux Corporation, including a portion of the proceeds. The United States' liens became effective as to other creditors upon the filing of the NFTLs referred to above. The priority of the United States' liens will be determined by application of 26 U.S.C. § 6323. E. Whether you claim a right to interest and, if so, the amount and basis for continuing accrual thereof, if any. Response: The United States claims a right to interest pursuant to 26 U.S.C. §§ 6601(a) and 6621(a)(2). The United States seeks $1,149,776.34, as of March 26, 2026, plus interest and statutory additions that will continue to accrue according to statutory law. F. Whether you claim a right to attorneys' fees. Response: N/A. The United States does not claim a right to attorneys' fees. G. For any creditor claiming a secured interest, identify the date(s) on which advances were made to Cyberlux or on its behalf for which any secured interest is claimed. Response: N/A. The United States did not advance money to Cyberlux. CERTIFICATION I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Carol Dans Dated: March 4, 2026 CAROL DAVIS Revenue Officer Internal Revenue Service
entityobservation

ELIZABETH PRUITT

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Case 3:25-cv-00483-JAG Document 175-23 Filed 04/15/26 Page 6 of 6 PagelD# 2919 Date: March 5, 2026 BRETT A. SHUMATE Assistant Attorney General JOSHUA WO Deputy Assistant Attorey General, Tax Litigation Brach Is/ William J. Harrington WILLIAM J. HARRINGTON Is/ Elizabeth W. Pruitt ELIZABETH PRUITT Trial Attorneys Tax Litigation Branch Civil Division, Department of Justice Post Office Box 227 Washington, DC 20044 Telephone: (202) 353-1882 (WJH) Telephone: (202) 353-7293 (EP) William.J.Harrington@usdoj.gov Elizabeth.Pruitt@usdoj.gov -and- TODD W. BLANCHE Deputy Attorney General Is/ Jonathan H. Hambrick Jonathan H. Hambrick VSB NO. 37590 Assistant United States Attorney Eastern District of Virginia 919 E. Main Street, Suite 1900 Richmond, VA 23219 Phone: (804) 819-5400 Fax: (804) 771-2316 E-mail: jay.h.hambrick@usdoj.gov CERTIFICATE OF SERVICE I certify that on March 5, 2026, I served the foregoing response upon counsel to all parties by email. Is/ Elizabeth Prett 5
inferenceinference

Exact arithmetic does not remove the express mixed-date qualification or establish priority over another claimant. The response must be pres

Exact arithmetic does not remove the express mixed-date qualification or establish priority over another claimant. The response must be presented with those qualifications.

otherattribution

Complete supplied 6-page source reviewed at SHA-256 c039a0519ec2aea6c7c7c5b3138a94bb31af58afcf2f713f3d0565c79d3b0e7a. Source assertions, ori

Complete supplied 6-page source reviewed at SHA-256 c039a0519ec2aea6c7c7c5b3138a94bb31af58afcf2f713f3d0565c79d3b0e7a. Source assertions, original visual features, filing/communication context and identified missing attachments are retained. Exact version_f28c4c382535409694c130b75dac637b; SHA256 c039a0519ec2aea6c7c7c5b3138a94bb31af58afcf2f713f3d0565c79d3b0e7a. Every page fully read and all substantive pages visually checked, including signatures, dates and monetary entries. Arithmetic checked independently; source assertions remain attributed.

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EXHIBIT 21 Case 3:25-cv-00483-JAG Document 175-23 Filed 04/15/26 Page 1 of 6 PageID# 2914
questionquestion

What account transcripts and accrual worksheets explain the forward March26 amounts, the February16 exception and any intervening payments o

What account transcripts and accrual worksheets explain the forward March26 amounts, the February16 exception and any intervening payments or additions?

questionquestion

What produced notices and underlying assessment records establish filing, property attachment and competing priority for these proceeds?

distillateallegation

CONNECT

Reviewed relationships

The canvas follows the database: source to DISTIL record, DISTIL record to knowledge object, then reviewed relationship. Position alone means nothing.

Table1 generally uses March26,2026 balances, but footnote1 expressly uses February16,2026 for the December2010 Form941 row. The displayed aggregate therefore combines balance dates; it is not a uniformly dated payoff. Assessment dates respectively are May13,2013; April11,2011; April1,2013; September5,2022; February27,2023; February26,2024; October24,2016.supportsIs $1,149,776.34 a uniformly dated balance or a loan claim?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
NFTL filing dates are April30,2024 for the first three and December2023 rows; October10,2023 for December2021 and December2022; August21,2017 for the section6721 penalty. The response asserts notice, demand, unpaid assessments and liens on Cyberlux property including the proceeds. It distinguishes assessment-time lien creation from effectiveness against other creditors through filing, and says priority will be determined under section6323. This is the claimant’s position, not a supplied priority ruling.supportsExact arithmetic does not remove the express mixed-date qualification or establish priority over another claimant. The response must be presented with those qualifications.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The United States claims $1,149,776.34 plus continuing interest and statutory additions. Seven rows sum exactly to that amount: Form941 June2010 $87,188.95; Form941 December2010 $149,003.11; Form941 December2012 $869,532.75; Form941 December2021 $2,617.01; Form940 December2022 $320.48; Form940 December2023 $358.73; section6721 December2013 penalty $40,755.31.supportsWhat account transcripts and accrual worksheets explain the forward March26 amounts, the February16 exception and any intervening payments or additions?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The United States claims $1,149,776.34 plus continuing interest and statutory additions. Seven rows sum exactly to that amount: Form941 June2010 $87,188.95; Form941 December2010 $149,003.11; Form941 December2012 $869,532.75; Form941 December2021 $2,617.01; Form940 December2022 $320.48; Form940 December2023 $358.73; section6721 December2013 penalty $40,755.31.supportsExact arithmetic does not remove the express mixed-date qualification or establish priority over another claimant. The response must be presented with those qualifications.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
EDVA175-23 Exhibit21 filed April15,2026 preserves the United States discovery response. Revenue Officer Carol Davis signs under penalty of perjury dated March4,2026. Counsel response and email-service certificate are dated March5,2026, with the day handwritten; the certificate carries Elizabeth Pruitt’s ink signature. These dates precede the main stated March26 balance date.supportsWhat account transcripts and accrual worksheets explain the forward March26 amounts, the February16 exception and any intervening payments or additions?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Both production responses state supporting documents were produced February19,2026 as USA0001–15. Those fifteen Bates pages are not attached to this six-page exhibit. Production assertion does not itself permit examination of the assessments or notices.supportsWhat produced notices and underlying assessment records establish filing, property attachment and competing priority for these proceeds?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
NFTL filing dates are April30,2024 for the first three and December2023 rows; October10,2023 for December2021 and December2022; August21,2017 for the section6721 penalty. The response asserts notice, demand, unpaid assessments and liens on Cyberlux property including the proceeds. It distinguishes assessment-time lien creation from effectiveness against other creditors through filing, and says priority will be determined under section6323. This is the claimant’s position, not a supplied priority ruling.supportsWhat produced notices and underlying assessment records establish filing, property attachment and competing priority for these proceeds?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The United States expressly claims no attorneys’ fees and states it did not advance money to Cyberlux. The claim described here is unpaid tax and penalty liability, with continuing statutory interest, rather than a loan or procurement-loss demand.supportsIs $1,149,776.34 a uniformly dated balance or a loan claim?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Table1 generally uses March26,2026 balances, but footnote1 expressly uses February16,2026 for the December2010 Form941 row. The displayed aggregate therefore combines balance dates; it is not a uniformly dated payoff. Assessment dates respectively are May13,2013; April11,2011; April1,2013; September5,2022; February27,2023; February26,2024; October24,2016.supportsExact arithmetic does not remove the express mixed-date qualification or establish priority over another claimant. The response must be presented with those qualifications.

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
The United States claims $1,149,776.34 plus continuing interest and statutory additions. Seven rows sum exactly to that amount: Form941 June2010 $87,188.95; Form941 December2010 $149,003.11; Form941 December2012 $869,532.75; Form941 December2021 $2,617.01; Form940 December2022 $320.48; Form940 December2023 $358.73; section6721 December2013 penalty $40,755.31.supportsIs $1,149,776.34 a uniformly dated balance or a loan claim?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%
Table1 generally uses March26,2026 balances, but footnote1 expressly uses February16,2026 for the December2010 Form941 row. The displayed aggregate therefore combines balance dates; it is not a uniformly dated payoff. Assessment dates respectively are May13,2013; April11,2011; April1,2013; September5,2022; February27,2023; February26,2024; October24,2016.supportsWhat account transcripts and accrual worksheets explain the forward March26 amounts, the February16 exception and any intervening payments or additions?

Specifically named source propositions support the bounded distinction or question.

50%
Confidence 75%Link weight 50%

WEIGH

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