CPA Jack Fisher, called a pioneer in the sale of such tax shelters, began selling units in the shelters as early as 2008 with James Sinnott, a CPA and attorney, joining the scheme in 2013. Sinnott oversaw what was described in a press release from the Department of Justice as a “massive expansion of the tax shelters.” The conspirators received more than $41 million in payments. They also used deductions generated by their tax shelters on their own personal income tax returns to reduce taxes they owed on the millions earned.

The duo used such actions as inflated appraisals and backdated documents to generate the tax deductions.

Fisher and Sinnott used proceeds to purchase luxury items, including a Mercedes Benz car, a recreational vehicle and trailer and a private jet. Fisher also purchased homes and condos in the United States and on the Caribbean Island of Bonaire, which the jury found to be forfeitable.

Fisher was ordered to pay about $457,855,755 in restitution to the United States while Sinnott was ordered to pay $443,760,035 in restitution.

Two other CPAs, Victor Smith and William Tomasello, both Atlanta-area CPAs, pleaded guilty this month to conspiracy to defraud the United States but have not been sentenced. Six other professionals have previously pled guilty—CPAs Walter Douglas “Terry” Roberts, Stein and Corey Agee, Ralph Anderson, and James Benkoil and CPA and Attorney Randall Lenz. Fisher’s primary assistant, Kate Joy, who was also indicted, remains a fugitive.