The Golf Course Gambit

Michael Kirouac owned or controlled four companies: HK Manchester, HK Loudon, HK Hudson, and HK Pelham. Prosecutors said he applied for and obtained more than $1 million in Economic Injury Disaster Loans, certifying that the money would be used solely as working capital and not for personal expenses or business relocation. 

But when Kirouac wanted to purchase Angus Lea Golf Course and could not obtain financing from banks or private lenders, prosecutors said he used approximately $600,000 of EIDL funds intended for HK Manchester and HK Loudon to help buy the course. He also obtained a $260,500 EIDL for HK Hudson after he had already agreed to sell that business, without disclosing the sale agreement to the SBA. 

Kirouac pleaded guilty to wire fraud on October 3, 2025, and was sentenced on February 19, 2026, to 15 months in prison and one year of supervised release. 

Jason explains why restricted government relief funds are not flexible deal money, how EIDL misuse can become a criminal case, and what business owners should do before moving loan proceeds into acquisitions, personal expenses, related entities, or new ventures. 

Key Takeaways:

• Restricted funds must be used for restricted purposes. 
• Loan certifications are evidence, not administrative clutter. 
• A failed financing search does not justify using government relief money as acquisition capital. 
• If a business owner has already misused restricted funds, the first move is to stop, preserve records, and get privileged legal review before creating more documents. 
• The goal is to fix the issue while it can still be handled as a civil tax, loan, or administrative problem whenever possible. 

Suggested Timestamps:

00:00: Cold open, COVID relief money and a golf course 

00:30: Branded intro, Final Notice: Real Tax Cases. Exposed. 

00:45: Who Michael Kirouac was 

01:45: The four HK companies 

02:30: What EIDL funds were supposed to be used for 

03:30: The golf course financing problem 

04:30: The Angus Lea Golf Course purchase 

05:45: Why EIDL misuse creates a paper trail 

06:45: HK Hudson and the undisclosed sale issue 

07:45: Guilty plea and sentencing 

08:30: What he should have done instead 

10:00: Legitimate financing alternatives 

11:00: What to do if restricted funds were already misused 

12:00: Final lesson, restricted funds are restricted for a reason 

12:45: Close and call to action 

Resources Mentioned:

• DOJ sentencing release: https://www.justice.gov/usao-nh/pr/pembroke-man-sentenced-misusing-cares-act-funds-purchase-angus-lea-golf-course 
• IRS-CI sentencing release: https://www.irs.gov/compliance/criminal-investigation/pembroke-man-sentenced-for-misusing-cares-act-funds-to-purchase-the-angus-lea-golf-course 
• The Law Office of Jason Carr, PLLC: https://carrtaxlaw.com 

Transcript

SPEAKER_00 0:06

You're listening to Final Notice. Real Tax Cases Exposed with Jason Carr. Each week we break down real Department of Justice tax fraud prosecutions and reveal what should have been done to avoid them. And now here's your host, Jason Carr.

SPEAKER_01 0:29

Over a million dollars in COVID relief funds, four companies, one golf course, and a financing problem that turned into a federal wire fraud conviction. Today's case starts in New Hampshire with a man named Michael Kirovak. Kirovak was from Pembroke. According to the government, he owned or controlled four companies, H.K. Manchester, H.K. Loudoun, HK Hudson, and H.K. Pelham. Those names matter because each company became part of the story. During the early part of the COVID pandemic, Congress created relief programs under the CARES Act. One of those programs was the Economic Injury Disaster Loan Program, usually called EIDL or IDL. Idle funds were supposed to help businesses with working capital and business expenses such as payroll, rent, and mortgage costs. Kerouac applied for and obtained more than one million dollars in IDL funds for his companies. When he signed for those funds, he certified that the money would be used solely as working capital, not for personal expenses, and not to relocate the businesses. That certification is not decoration. It's not fine print in the way that people like to pretend fine print doesn't count. It is the part where the borrower tells the government, I understand what this money is for, and I'm going to use it that way. Then came the golf course. According to prosecutors, beginning in 2021, Kirovac was looking to buy Angus Lee Golf Course in Hillsborough, New Hampshire. He could not get financing from banks or private lenders. That's usually the moment where a business owner needs to pause, reassess, restructure the deal, bring in investors, reduce the purchase price, or walk away. Instead, prosecutors say Kiroack obtained IDO funds on behalf of HK Manchester and HK Loudoun and use approximately $600,000 of those funds to help purchase the golf course. That is the gambit. Pandemic relief money intended for business working capital became acquisition financing for a golf course. While investigation steps aren't spelled out, the path to getting caught here is pretty clear. First, government funds leave a paper trail. There is an application, there are certifications, there are bank records, there are disbursements, there are transfers, there are closing documents when real estate or a business asset is purchased. You don't secretly buy a golf course. That is not like a pair of shoes. That is not a stake dinner. That is a transaction with lawyers, lenders, escrow, titlework, wires, operating records, and public facing business activity. According to the government, Kerouck obtained idle funds for HK Manchester and HK Loudoun, then used approximately six hundred thousand dollars of those funds to help buy Angus Lee golf course. Prosecutors also said he misused idle funds obtained for HK Pelham. Then there was HK Hudson. Kerouac separately obtained a two hundred sixty thousand five hundred dollar idol loan for HK Hudson, but according to prosecutors, he had already agreed to sell HK Hudson to a third party when he signed for the loan, and he did not disclose that fact to the SBA. That's a major problem. If you're applying for disaster relief funds for a business and you have already agreed to sell that business, that fact is important. The government wants to know who is actually operating the business, who suffered the economic injury, who needs the working capital, and whether the applicant is eligible for the funds. The investigation was led by the Department of Veterans Affairs Office of Inspector General, IRS Criminal Investigation, and the SBA Office of Inspector General. That mix tells you the case was treated as a financial fraud matter involving federal relief funds, not just a paperwork mistake. Kerouek pleaded guilty to one count of wire fraud on October third, twenty twenty five. On February nineteenth, twenty twenty six, he was sentenced to fifteen months in prison and one year of supervised release. Fifteen months. For a business owner, that is not an accounting adjustment. That is prison. That is supervised release. That is a federal conviction. That is the kind of problem that changes every future conversation with lenders, regulators, customers, insurers, and business partners. Now let's answer to the question the show always asks. What would I have told Michael Kirovak if he'd come to me before this happened? First, I would have separated the business problem from the funding fantasy. The business problem was simple. He wanted to buy a golf course and could not get conventional financing. That happens. Deals fail financing all the time. There is nothing criminal about wanting to buy an asset and being turned down by lenders. The problem starts when restricted government funds get treated like flexible deal money. Idol funds were not general entrepreneurial capital. They were intended for working capital and business expenses for eligible businesses harmed by the pandemic. If a borrower certified that funds would be used only for permitted purposes, the first move is to respect that certification. Second, I would have reviewed the loan documents before any dollar moved. Not after the closing, not after the audit letter, not after an agent calls. Before. A business owner should know exactly what the funds can be used for, what they cannot be used for, what records must be kept, what certifications were made, and what events require disclosure to the SBA or lender. If the use is questionable, get a written legal analysis before the money moves. Third, if the golf course deal still made sense, I would have looked at legitimate financing. That could mean seller financing, it could mean bringing in equity investors, it could mean forming a properly capitalized acquisition entity, it could mean a smaller purchase, a delayed closing, a management agreement with an option to buy, or simply walking away. Walking away from a bad financing structure is not failure, it's just good judgment. Fourth, if idle funds had already been misused, the strategy changes immediately. At that point, the question becomes, how do we keep this in the civil lane if possible? That means stopping the misuse, preserving records, reconstructing the flow of funds, correcting any false or incomplete information, and evaluating whether repayment, disclosure, or cooperation is appropriate. The longer a business owner waits, the worse the facts usually look. This is where attorney client privilege matters. You don't want the first serious analysis of the problem happening in an email chain with your bookkeeper, lender, business partner, or buyer. You want a protected review of the facts before anyone starts explaining things in writing. And if you're a tax professional or business advisor listening to this, the lesson is straightforward. When a client wants to use restricted funds for a new venture, acquisition, personal purchase, or unrelated entity, stop the conversation and review the program rules. Do not let cash is cash become the operating theory. Cash is not always cash. Sometimes cash comes with certifications, restrictions, and investigators. The lesson from this case is simple. Restricted funds are restricted for a reason. If the government gives a business money for working capital, don't treat it like acquisition financing. If the loan application says the money cannot be used for personal expenses, relocation, or other purposes, believe the application. If your deal only works because you're about to use funds in a way you promise not to use them, the deal does not work. A golf course may be a business opportunity, but pandemic relief funds are not a shortcut around lenders who said no. I'm Jason Carr, tax attorney. If you want to make sure you never end up on this podcast, you know where to find me. Cartaxlaw.com. Link is in the show notes. This has been Final Notice, Real Tax Cases Exposed.

SPEAKER_00 8:03

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