Comment from Taxpayers Against Unethical Corporate Fraud

SUPPLEMENTAL FORENSIC REGULATORY COMMENT REGARDING SECTION 45Z CLEAN FUEL PRODUCTION CREDIT Docket ID: REG-121244-23 / IRS-2026-0133 Filing Date: June 24, 2026 Submitted By: Evan H. Couture, Lead Auditor of the r/equinetarian Archive I. THE SUBVERSION OF CONSUMER SOVEREIGNTY AS REGULATORY CAPRICE The proposed Section 45Z framework creates a severe market distortion by actively insulating industrial producers from standard free-market accountability. In a functional market economy, consumer choice and voluntary boycotts serve as the primary democratic check against corporate malpractice, pollution, and ethical degradation. If consumers refuse to fund an industry due to its operational externalities, that industry must reform or face liquidation. By inserting a multi-billion dollar taxpayer-funded subsidy into the value chain, the Internal Revenue Service is establishing an artificial shield. This mechanism forces citizens into a state of involuntary financial complicity. A taxpayer can meticulously boycott factory-farmed products or unsustainable fuels at the point of sale, yet the Service utilizes the tax code to automatically route their income into the balance sheets of the exact corporations being boycotted. Forcing captive taxpayers to capitalize industries they actively oppose is a severe distortion of market mechanics that undermines the statutory intent of public benefit. II. STRUCTURAL PARALLELS TO CIVIL CHARITABLE FRAUD The Petitioner requests that the Service audit the structural architecture of the 45Z credit against established federal definitions of white-collar diversion and charitable fraud. When a private entity solicits donations under an altruistic banner—such as "environmental stewardship" or "climate relief"—but engineers its internal allocation metrics to distribute those funds directly to preferred corporate insiders while shutting out small-scale, independent operators, it is prosecuted as fraud. But under sovereign immunity and “expert guidance” the Agency has effectively done just this. The Section 45Z credit mirrors this exact diversionary blueprint: The Altruistic Banner: The program is marketed under the high-minded guise of "decarbonization" and "clean fuel production." The Structural Diversion: The actual mechanics of the rule—specifically the multi-million dollar capital requirements for anaerobic digesters and complex traceability software—create an artificial financial moat. This moat systematically locks out small, pasture-based agricultural producers who prevent emissions at the source without creating environmental crises. The Enrichment Loop: Concurrently, the rule funnels billions in public resources to massive industrial conglomerates who concentrate waste specifically to harvest the "negative integer" credit.. CONCLUSION & DEMAND To subsidize the imperfect capture of a pollutant flux that the industry intentionally generated is not climate stewardship; it is a state-sanctioned financial diversion. The IRS must reject this framework. Anything less constitutes an administrative "math fudge" that transforms the American tax code into a forced bailout mechanism for specialized industrial interests that violates the spirit of the free market and renders consumer choice useless against a mandatory funding of even harmful industries through tax money. Respectfully submitted, Evan H. Couture