Exhibit 607

DEPARTMENT OF THE TREASURY

Internal Revenue Service
Criminal Investigation

Memorandum of Interview

Investigation #: Location: USAO Delaware – Conference

Room
Investigation Name: Robert DOE
Date: November 16, 2021
Time: Approx. 3:01PM –
4:30PM
Participant(s): Troy Schmidt, RHB’s Return Preparer
Phil Carney, Schmidt’s Counsel
Joseph A Ziegler, Special Agent, IRS-CI
Christine Puglisi, Special Agent, IRS-CI
Michelle Hoffman, Forensic Accountant, FBI
Jack Morgan, Department of Justice – Tax
Mark Daly, Department of Justice - Tax

On the above date and time, SA Ziegler, SA Puglisi, FA Hoffman, DOJ-Tax Attorney
Morgan and DOJ-Tax Attorney Daly met with Troy Schmidt (“Schmidt”) and his
attorney, Phil Carney at the above location. This interview had been set up prior to the
meeting. , had noted that
RHB had withdrawn some of his claims of privilege relating to the return preparation
documents,

Schmidt provided the following information.

1. Schmidt stated that he would track his time in the same manner that Jeff
Gelfound (“Gelfound”) would have kept his. Schmidt stated that his timesheet
might have less detail though because he is a partner and his ability to keep
track of time is more relaxes. Schmidt stated that that his assistant ultimately
submits Schmidt’s time into the billing system. Schmidt stated that he turned
over his detailed timesheets at the same time Gelfound did.

a.

2. Schmidt stated that George Mesires’ (“Mesires”) role in RHB’s return

preparation process was helping them get information for RHB in helping
prepare RHB’s unfiled tax returns. Schmidt stated that Mesires did not give them
a heads up on advice of working with RHB and what they needed to pay
attention to. Mesires helped them get information from RHB’s prior accountants
as they were initially reluctant in turning over information to them. Schmidt

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 stated that they were instructed to send all communications regarding RHB to
Mesires.

3. Schmidt couldn’t recall why RHB had unfiled tax returns. Schmidt did recall that
the reasons were just excuses: RHB had been through a difficult divorce, his
prior accountant had passed away, he had been going through difficult times
and that he had a breakup with his former business partner.

4. Schmidt stated that his first communication with RHB was around their first
meeting on November 11, 2019. Schmidt stated that they were provided with
RHB’s draft tax returns out of that meeting and that they started their review of
RHB’s tax returns. Schmidt stated that in the beginning, they were trying to
gather as much information as possible. Gelfound would have drafted the first
open items listing.

5.

a. Schmidt stated that he would send these emails to Mesires. Schmidt was
asked about item #10 and Schmidt stated that it was always a “challenge”
in getting source documents. If they would identify something that was
missing, Schmidt/ Gelfound would ask Mesires. If Mesires didn’t know,
Mesires would repeatedly point them in the right direction to get the
source documents, which would include the Wells Fargo bankers, RHB
and the accountants with Morgan Wingate.

b. Schmidt stated that they did have a draft of the Morgan Wingate prepared
2017 tax return and that they would ask for support of every line item.

6. asked about #10:

a. Schmidt doesn’t believe that they ever got an answer to this item.
Schmidt recalled that Bill Morgan (“Morgan”) had passed away and that
Merritt Wingate (“Wingate”) didn’t work on the RHB tax engagement. It
was apparent that Wingate wasn’t knowledgeable on the RHB’s tax
details.

b. Schmidt stated that they probably followed the treatment used for RHB in
the prior tax years.

7. asked about item #14:

a. Schmidt stated that this was a general question. Schmidt was asked if
they would push back on the treatment of tax deductions. Schmidt stated
that they would look at the deductions for reasonability and if it “looked
like” a business deduction. Schmidt stated that if there was a larger issue
with something in the records, that it would be the partner’s job
(Schmidt’s) to step in and add some muscle.

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 b. Schmidt stated that there was an instance with RHB where he needed to
step in and that it was mainly on the income side. RHB was telling that
the money he received was a loan to him. RHB was unable to provide
loan documentation when asked for support. Schmidt stated that they got
the tax returns for the entity that had paid Owasco and that the tax return
did not show the money paid to Owasco as a loan. That entity actually
expensed the payments made to Owasco. At the end of the day, RHB
backed down and ultimately agreed that the payments to him were not a
loan.

8.

a. Schmidt stated that it took a while to get through to the right people in
getting source documents. Schmidt pointed at the amount of time it took
to get some of the documents. Schmidt wasn’t surprised that Mesires
didn’t have the information and stated that Schwerin was ultimately very
helpful in getting them information.

9. asked about the entry on January 17th:

a. Schmidt didn’t recall seeing the notes from the call. Schmidt stated that in
addition to gathering documents, Mesires was also reviewing drafts of the
tax returns.

b. Schmidt didn’t recall going through in detail the drafts of the tax returns
with Mesires. But that they went over some items on the tax returns.

c. Schmidt didn’t recall Mesires or Asheef (sp) coming back with any issues
on the draft tax returns.

10. entry on January 18th

a. Schmidt stated that these looked like his notes and that he felt at the time
like they needed to be typed up. Schmidt recalled being surprised that
they 2016 tax return had not been filed and that everyone had assumed it
had been filed. Schmidt stated that Mesires and RHB tried to get the tax
lien resolved. Mesires wanted to avoid a public tax lien and that they
were trying to work out an extension with the IRS and/ or get the taxes
paid right away. Schmidt also recalled telling Mesires about the 2016 tax
return not being filed.

11. Schmidt did not recall anyone telling him about RHB omitting Burisma income
from the 2014 tax return and/ or that RHB needed to file an amended tax return
for 2014.

12.

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 a. Schmidt stated that these were his notes from the crisis meeting at Kevin
Morris’ (“Morris”) home in the Pacific Palisades. Either Morris or Morris’
assistant had invited Schmidt to this meeting and Schmidt stated that at
the time, he had no idea what he was walking into. Schmidt stated that
the meeting lasted 2 ½ hours.

b. Schmidt stated that Morris had first appeared two days prior to this
meeting.

c. Schmidt didn’t recall the exact purpose of the crisis meeting, Schmidt
originally thought that they were going to discuss RHB’s returns, but that
they didn’t end up discussing anything about the preparation of RHB’s tax
returns. Schmidt stated that at least ten people were at the meeting and
that he didn’t end up documenting everyone at the meeting. Schmidt
recalled Mesires, RHB, Morris and Lindsey Wineberg at the meeting.

d. Schmidt stated that Morris’ role was another advisor to RHB and RHB’s
family. Schmidt was not surprised that a lot of attorneys were working for
RHB.

13.

a. Schmidt would review documents with Gelfound and either Schmidt and/
or Gelfound would send them to Mesires as he was the point guy in
RHB’s return preparation. Schmidt and / or Gelfound were not
communicating with RHB at this point because that’s what they were
instructed to do.

b. Schmidt was sure he discussed these reports with Gelfound. Schmidt

stated that they were creating RHB’s books and records from scratch and
were going off of QuickBooks entries they had input from the bank
statements. Schmidt stated that their bookkeeper had made the initial
classification and that RHB was instructed to identify personal
expenditures.

14.

a. Schmidt couldn’t recall having a call with Mesires before sending the
email. Schmidt didn’t recall discussing the reports in detail with Mesires.
Schmidt stated that this Exhibit showed expenses that were questionable.

b. Schmidt stated that they never discussed these reports with Morris.
Morris was not involved in the tax return prep.

15. entry dated January 27th.

the representation letter in their workpapers.

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 a. Schmidt stated that this letter evolved out of the return preparation
process. Schmidt stated that RHB was a high-profile individual and that
they had to rely on RHB’s statements in the return preparation process.
Schmidt wanted to make sure that there was no mistake on reliance in
the return preparation. Schmidt further stated that he wanted to make
sure that there was “no misunderstanding later on”. Schmidt stated that
they had difficulty in getting information from RHB and his representatives
and that they were missing information. Schmidt thought that it was
significant enough to get this representation letter.

b. Schmidt stated that the letter did not come up as a snap decision.
Schmidt stated that he would have discussed this representation letter
with the other partners. Schmidt stated that they got a draft of the
representation letter from their insurance provider Camico website and
that they tailored the letter to RHB’s situation.

16.

a. Schmidt recalled the meeting. Schmidt stated that they were constantly
asking for the same things from RHB. Schmidt didn’t recall discussing or
educating RHB on what was a proper business deduction, but Schmidt
stated that RHB knew what a proper business expense was.

b. Schmidt was asked about item 6. Schmidt stated that they must have
reviewed this in detail with RHB.

c. Schmidt was asked about the January 25th report in the workpapers.
Schmidt recalled RHB highlighting items and going through the report.
Schmidt stated that they might have also discussed some of the items.
Schmidt recalled him and Gelfound sitting with RHB as he went through
these statements and that they were there to answer any questions he
had.

d. Schmidt recalled giving a stack of bank statements to RHB, and that he

took them home to review. Schmidt stated that RHB did take the
statements home and that he brought them back after he reviewed them.

17.

a. Schmidt was sure that they had a discussion with RHB about the
Ridgewood and Chase items. Schmidt stated that based on these
discussions they decided that the payments were deductible and that
they were never able to get evidence to the contrary. Schmidt stated that
they would have asked for backup documentation for these items.

b. Schmidt recalled having pressure from RHB and his attorneys at this time
to get the returns completed and filed with the IRS.

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 c. Schmidt didn’t recall what RHB stated about the Ridgewood Savings
expenditures. Schmidt recalled that some of the payments went to RHB’s
uncle, James Biden (“James B”). Schmidt recalled that they had originally
classified something as being paid to James B that didn’t actually go to
James B.

d. Schmidt stated that RHB recalled what certain bank accounts were used
for and that they were business expenses, but that he couldn’t recall the
specifics. Schmidt stated that they would have just relied on the
statements made by RHB about the expenditures.

18.

a. Schmidt recalled that BHR was a Chinese investment stat RHB was
involved in. Schmidt couldn’t recall what was said about the initial source
of the funds for the $450,000 investment. Schmidt stated that the
investment was prior to 2017 / 2018.

b. Schmidt stated that if he received background information on BHR that it

would be in the workpapers / notes. Schmidt recalled telling Gelfound to
take good notes.

19. Schmidt couldn’t recall if he was at the next meeting on January 30th with RHB.
Schmidt stated that he didn’t attend 100% of the meetings with RHB and that he
would have to look back at his own schedule.

20. Schmidt recalls the next meeting on February 6th. Schmidt stated that the 2018
workpapers were shown to RHB and that they went over some of the same
issues. Schmidt stated that they had issued Forms 1099 for payments made
from Owasco. Schmidt recalled receiving a phone call from Sara Biden (“Sara
B”) who was disputing the amount shown on the Form 1099. Schmidt recalled
this being related to the payments made to a Chase account that were classified
as being paid to James B and Sara B. Schmidt recalled he and Gelfound trying
to get support for these Chase payments and that it was a mystery to them why
they couldn’t get it. Schmidt recalled constantly asking for this support. Schmidt
recalled that RHB wasn’t able to access some of the records because the
accounts were closed. Schmidt recalled that RHB’s banker at Wells Fargo also
weren’t able to get the support and that RHB had insisted that the unknown
payments were business related.

21. Schmidt stated that the 80 / 20 split on the line of credit was decided in one of
the late meetings with RHB. Schmidt stated that they had got some sense of
what RHB would have used the line of credit for based on discussions with
RHB. RHB had represented to Schmidt that the line of credit was mostly used
for travel and that’s why they came up with the split.

22. DOJ-Tax Attorney Daly asked Schmidt what type of business was RHB doing
during 2018. Schmidt stated that RHB had traveled extensively for business as

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 a consultant and that he had international business he was doing as well. RHB
did not discuss his substance abuse issues in 2018 with Schmidt.

23. DOJ-Tax Attorney Daly had pointed out

that the travel account was 13 times more in 2018 than in 2017:

a. Schmidt stated that the Travel Transportation and other account

encompassed stuff that they didn’t have supporting documentation for.
Schmidt recalled telling RHB that if he was audited, they would have to
find documentation for these items and that the IRS could thrown them
out. Schmidt recalled that RHB said if the return had to be amended, that
he would amend it.

24.

a. Schmidt stated that this was an effort to send the returns to everyone and
to notify them that they don’t have support for some of the items. Schmidt
stated that they were expressing this concern to RHB’s counsel and that
nobody called after they sent this email. Schmidt stated that they may
have had an email that the returns look fine. Schmidt stated that they
ended up filing the returns so they must have received a response, with
no changes. Schmidt stated that he wasn’t sure if any of the attorneys
actually reviewed the tax returns, but that there were no comments made
and no changes suggested.

b. Schmidt stated that no body had asked them to delay filing the returns or
to slow down the process. Schmidt recalled RHB trying to go online to get
his tax account transcripts. Schmidt stated that they never received the
support.

c. Schmidt does not recall the name Shep Hoffman. Schmidt stated that the
“personally and politically” statement delves into the other areas and that
they were again, under a significant amount of pressure to file the tax
returns.

25. Schmidt recalled RHB signing the returns on February 11th and that Schmidt
had a meeting the day before, with Ed White and another partner at the firm
Rick Finnestrom. At this meeting they discussed the outstanding matters with
RHB’s returns and where they stood in filing them. Schmidt looked at this
meeting as an internal review process and to ask the other partners if they had
missed anything.

26. Schmidt again verified that they never got the line of credit records from RHB.

27. Schmidt stated that they did not amend the 2018 tax return due to the
discrepancy with Sara B and James B’s 2018 payments because they never got
additional support that disproved the expenditures were not business related.

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 28. Schmidt was asked about the final review with RHB of the tax returns. Schmidt
stated that they went over with RHB the final numbers, the bottom-line number,
the income and tax due. Schmidt was asked if RHB had any comments about
the returns. Schmidt stated that the “tax due” opened his eyes. RHB didn’t
indicate to Schmidt how he was going to pay the tax due. Schmidt recalled
discussing a payment plan with RHB. Schmidt again stated that RHB definitely
went through the returns and that he was aware of the open items they had at
the time of filing.

I prepared this memorandum over December 17 through December 28, after

refreshing my memory from notes made during and immediately after the interview
with Troy Schmidt.

Joseph A. Ziegler
Special Agent

Christine Puglisi
Special Agent

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