DENVER - A federal jury in the District of Colorado convicted four individuals of conspiracy to defraud the United States through an abusive trust tax evasion scheme that caused approximately $40 million in losses, the Department of Justice announced.
Marcia Predmore, a registered life insurance agent; Roderick Prescott; Suzanne Thompson; and Weldon Wulstein, a CPA, promoted an illegal “layered” trust tax shelter to hundreds of high-net-worth business owners nationwide. “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.”
The shelter consisted of four trusts — a business trust, family trust, charitable trust, and private family foundation — and taught clients to evade federal income taxes on upwards of 98% of their business profits by claiming deductions for non-deductible personal living expenses and fraudulent charitable contributions. The scheme cost clients between $25,000 to $50,000 to set up and was marketed at seminars across the country, advertising that participants could “own nothing, control everything.”
“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,” said Amanda Prestegard, Special Agent in Charge of the IRS Criminal Investigation Denver Field Office. “IRS-CI will continue to partner with DOJ-Tax to pursue these criminal tax evaders.”
Wulstein prepared hundreds of false tax returns for clients who purchased the shelter, working 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 and taught clients how to claim deductions for funds donated to the foundation while maintaining personal control over those funds.
Predmore promoted the shelter through a business she operated with her spouse, Timothy McPhee, who was sentenced in December 2025 to 151 months’ imprisonment for conspiracy, tax evasion, and wire fraud stemming from his role in the scheme and a separate multi-million-dollar investment fraud called the ROI Cash Flow Fund. Thompson and Wulstein were also convicted of six counts each of assisting in the preparation of false tax returns. Predmore was convicted of six counts of tax evasion for her personal use of the same shelter she sold to others.
All four defendants each face a maximum penalty of five years in prison for the conspiracy charge. Thompson and Wulstein face an additional maximum of three years per count for the false-return charges, and Predmore faces an additional maximum of five years per count for tax evasion. A federal district court judge will determine sentences after considering the U.S. Sentencing Guidelines. The DOJ noted the case supports President Trump’s Task Force to Eliminate Fraud, chaired by Vice President J.D. Vance, which was established alongside the National Fraud Enforcement Division announced April 7.