The problem, the lawsuit contends, is that Second Chance and NoVaStar have known for many years that (1) the IRS audited consumers and did not allow tax refunds or deductions for house donations made to Second Chance, and (2) that NoVaStar’s appraisals were IRS non-compliant. According to the complaint, despite this knowledge, Second Chance and NoVaStar concealed that information from Maryland consumers, including Gogtay and Dixit.