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.
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DISTILLATES
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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.
Read the anchor · page 3
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
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
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
Read the anchor · page 4
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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