A federal jury in the District of Colorado convicted four individuals today of conspiracy to defraud the United States for their operation of an abusive trust tax evasion scheme that caused approximately $40 million in losses to the United States.

"The defendants orchestrated an abusive trust tax scheme designed to help clients evade their tax obligations through a web of sham trusts, false representations, and fraudulent transactions," said Colin M. McDonald, Assistant Attorney General for the National Fraud Enforcement Division. "Tax fraud schemes undermine the integrity of our tax system and deprive the government of resources, shifting the burden to honest Americans who follow the law. Today's trial convictions underscore the Fraud Division's commitment to holding accountable those who promote and profit from abusive tax shelters and other fraud schemes."

"These defendants were repeatedly warned by attorneys, CPAs, financial professionals, and IRS guidance that this trust-based scheme was illegal, yet they chose to ignore those warnings. Their conspiracy was a deliberate attempt to conceal income and undermine the integrity of our nation's tax system while lining their own pockets through their lies," said Amanda Prestegard, Special Agent in Charge, IRS-CI Denver Field Office. "We appreciate the jury's verdict and the message it sends to those who promote or engage in abusive tax schemes. IRS-CI will continue to partner with DOJ-Tax to pursue these criminal tax evaders."

According to court documents and evidence presented at trial, Marcia Predmore, Roderick Prescott, Suzanne Thompson and Weldon Wulstein promoted an illegal "layered" trust tax shelter to hundreds of high-net-worth business owners nationwide. The tax shelter was made up of four trusts called a business trust, family trust, charitable trust, and private family foundation. The four promoters taught clients how to use the layered trust tax shelter to evade paying federal income taxes on upwards of 98% of their business profits, in part by claiming a tax deduction for non-deductible personal living expenses and fraudulent charitable contributions. Some of the promoters marketed this tax shelter at seminars hosted across the country and advertised that using the tax shelter would allow clients to "own nothing, control everything." The tax shelter cost between $25,000 to $50,000 to set up.

Wulstein, a CPA, prepared hundreds of false tax returns for clients who purchased the tax shelter. He did so in partnership with Thompson, who operated a bookkeeping firm and prepared financial statements for the clients' trusts. Prescott, who had previously been convicted of tax evasion and permanently enjoined from promoting abusive tax shelters, promoted the so-called private family foundation, which was the final layer of the tax shelter. Prescott taught clients how to claim a tax deduction for funds donated to the foundation while maintaining control over those funds for their own personal benefit.

Predmore, a registered life insurance agent, promoted the tax shelter to clients through the business she operated with her spouse. In December 2025, Predmore's spouse, Timothy McPhee, was sentenced to 151 months' imprisonment for conspiracy, tax evasion, and wire fraud. Those charges stemmed from his role in this scheme and for his operation of a multi-million-dollar investment fraud scheme called the ROI Cash Flow Fund.

Suzanne Thompson and Weldon Wulstein were also convicted of six counts each of assisting in the preparation of false tax returns for clients who purchased and used the fraudulent tax shelter. Marcia Predmore was convicted of six counts of tax evasion for her personal use of the same tax shelter she promoted to others.

All four promoters each face a maximum penalty of five years in prison for conspiracy to defraud the United States. Thompson and Wulstein also face a maximum penalty of three years in prison for each count of assisting in the preparation of false tax returns. Predmore faces an additional maximum penalty of five years in prison for each count of tax evasion. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

IRS Criminal Investigation is investigating the case.

Trial Attorneys Lauren K. Pope and Patrick Burns of the Criminal Division's Tax Section are prosecuting the case.

On April 7, the Department of Justice announced the creation of the National Fraud Enforcement Division (Fraud Division). The Fraud Division is laser-focused on investigating and prosecuting those who commit fraud against the American people. The Department's work to combat fraud supports President Trump's Task Force to Eliminate Fraud, a whole-of-government effort chaired by Vice President J.D. Vance to eliminate fraud, waste, and abuse within Federal benefit programs.