Following the Federal Election Commission (FEC)’s record post-Citizens United fine against three Koch network-funded groups for illegally hiding the source of the funding for their political ads, Citizens for Responsibility and Ethics in Washington (CREW) today filed supplemental criminal and IRS complaints against the Center to Protect Patient Rights (CPPR), now known as American Encore, and its president Sean Noble for lying on the group’s tax returns.

In 2010, CPPR was the Koch brothers’ main funding group and Noble the central figure in distributing their political spending, including millions to the three Koch-funded groups, the 60 Plus Association, the American Future Fund, and Americans for Job Security. The FEC’s review of CREW’s complaint and the three groups’ settlements show that Noble and CPPR falsely claimed on the group’s tax returns that CPPR engaged in no political activity in 2010. Lying on tax forms is a federal crime.

“This is a simple case of lying to federal agencies,” CREW Executive Director Noah Bookbinder said. “The FBI, Department of Justice and IRS should all investigate and the IRS should begin an audit.”

According to the FEC’s general counsel’s office, there is a reasonable basis for concluding CPPR provided funds to the groups “for the purpose of furthering” independent expenditures and electioneering communications, clear political activity. In addition to their six figure civil penalties, the three Koch network groups committed to amending their FEC disclosures “to reflect CPPR as a donor with respect to the relevant independent expenditures,” with 60 Plus also amending with respect to the relevant electioneering communications.

“There is no valid basis to dispute the fact that money for the three groups’ political activity came to them through CPPR, a key Koch network group at the time, despite CPPR’s claims to the contrary,” Bookbinder said. “There is a clear violation of the law here.”

CREW first filed complaints against Noble, CPPR and the three Koch-funded groups in May 2014.