At this point, Jeffrey Epstein might wish for the Al Capone treatment — getting taken down for tax evasion rather than the bigger crimes alleged. It’s not clear from NBC’s report, however, whether the IRS would have a case for tax fraud. According to NBC’s forensic accounting, it seems Epstein has greatly exaggerated his charitable donations in press releases, but did that extend to tax reporting from his foundations as well as his own personal income tax filings?

Press releases from Jeffrey Epstein’s foundation paint the wealthy registered sex offender as a generous donor to large American hospitals, top-10 research universities and children and youth charities in the U.S. Virgin Islands, where he owns an island.

But Epstein’s largesse was much smaller than what he represented, according to an NBC News review of public records and interviews with officials at the institutions named as recipients of his gifts. In reality Epstein’s contributions, whether personal or via his foundation, were a drop in the bucket compared to the donations of other wealthy philanthropists like Bill Gates and Warren Buffett.

To be fair, Epstein’s wealth wasn’t as extensive as Gates’ or Buffet’s, either. We’ll get back to that in a second, but it’s no crime to not be as generous as either titan. Unless, that is, you’ve told the IRS that you’ve been that generous. The report from Laura Strickler and Shelby Hanssen is irritatingly ambiguous on potential tax issues, but it does include this passage:

NBC News reached out to 56 charities that were listed as grant recipients in multiple press releases from Epstein’s foundation or his foundation’s IRS filings between 2010 and 2017. Thirty-two organizations did not return requests for comment. Of the 24 organizations that responded, 10 said they had no record of any donations from Epstein or Gratitude America.

How many of the claims were from press releases, though, and how many from tax filings? The latter could get prosecuted, while the former would only add to Epstein’s reputation as a scumbag. At least one example appears to cross the line into potential tax fraud, but even that’s a bit vague:

For example, Epstein lists New York’s Metropolitan Museum of Art as a recipient of contributions from the Jeffrey Epstein Foundation between 2010 and 2012. According to a spokesperson for the museum, however, “The Metropolitan Museum of Art has not received any major donations from Jeffrey Epstein or his foundation, only that he purchased tickets to two benefits in the early 1990s.”

Since we don’t know the amount claimed on the tax filings, it’s left to the imagination what MoMA considers a “major” donation, as opposed to none at all, and what Epstein claimed to the IRS. It certainly sounds as though Epstein has been stretching the truth on his charitable donations, although there are clear incentives now in place for charities to deny any connections to Epstein, too. One has to believe that the IRS might be interested enough in the potential for fraud to take a closer look — at least now that the Department of Justice has also taken a belated second look at his sex-trafficking activities.

On the other hand, perhaps there’s not much to find. It’s not just Epstein’s charity that has been exaggerated. The New York Times thinks that Epstein’s wealth is vastly overestimated too:

Mr. Epstein is routinely described as a billionaire and brilliant financier, and he rubbed elbows with the powerful, including former and future presidents. Even after his 2008 guilty plea in a prostitution case in Florida, he promoted himself as a financial wizard who used arcane mathematical models, and he often dropped the names of Nobel Prize-winning friends. He told potential clients that they had to invest a minimum of $1 billion. At his peak in the early 2000s, a magazine profile said he employed 150 people, some working out of the historic Villard Houses on Madison Avenue.

Much of that appears to be an illusion, and there is little evidence that Mr. Epstein is a billionaire.

It’s not that Epstein isn’t fabulously wealthy — but that he may not be nearly as liquid as the feds believe, and as Epstein has portrayed himself:

Mr. Epstein, 66, is doubtless very rich: His real estate alone — one of Manhattan’s largest private mansions, a Palm Beach estate, a Paris apartment, his own Caribbean island and a huge New Mexico ranch — is worth more than $200 million. His investment firm reported having $88 million in capital from its shareholders in 2002. …

A corporate disclosure form from 2002 portrays a less impressive picture. Thomas Volscho, a sociology professor at the College of Staten Island who has been researching for a book on Mr. Epstein, recently obtained the form, which shows Financial Trust had $88 million in contributions from shareholders. In a court filing that year, Mr. Epstein said his firm had about 20 employees, far fewer than the 150 reported at the time by New York magazine.

Frankly, having $200 million in real estate would qualify as high-end wealthy for most people. His liquidity might be in question, and his overall net worth might have dropped significantly in the Great Recession, as the NYT reports. But if Epstein managed to hold onto all his mansions and his Caribbean island, it’s a fair bet that he’s managed to hold onto enough of his net worth to make the “billionaire” appellation accurate enough.

If the IRS does pick up this thread, we might get a more accurate picture of Epstein’s empire. But if they do, the IRS might also have to answer why they didn’t keep closer tabs on Epstein all along, too.