Four Colorado residents were convicted by a federal jury of conspiracy to defraud the United States for their roles in an abusive trust tax evasion scheme that caused approximately $40 million in losses to the United States, the Justice Department announced.

Marcia Predmore, Roderick Prescott, Suzanne Thompson and Weldon Wulstein promoted an illegal “layered” trust tax shelter to hundreds of high-net-worth business owners across the country, according to court documents and evidence presented at trial. The scheme used four trusts — a business trust, family trust, charitable trust and private family foundation — to help clients evade federal income taxes on upwards of 98% of their business profits, prosecutors said.

The defendants taught clients to claim tax deductions for non-deductible personal living expenses and fraudulent charitable contributions, according to the Justice Department. Some promoters marketed the shelter at seminars nationwide, advertising that using it would allow clients to “own nothing, control everything.” The tax shelter cost between $25,000 and $50,000 to set up.

“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.

Wulstein, a CPA, 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, according to the Justice Department. Prescott, who had previously been convicted of tax evasion and permanently barred from promoting abusive tax shelters, promoted the private family foundation layer of the scheme, teaching clients how to claim deductions for donations to the foundation while maintaining control over those funds for their own personal benefit, prosecutors said.

Predmore, a registered life insurance agent, promoted the shelter through a business she operated with her spouse, Timothy McPhee. In December 2025, McPhee was sentenced to 151 months in prison for conspiracy, tax evasion and wire fraud related to his role in the scheme and his operation of a separate multi-million-dollar investment fraud called the ROI Cash Flow Fund, the Justice Department said.

Thompson and Wulstein were each convicted on six additional counts of assisting in the preparation of false tax returns. Predmore was convicted on six counts of tax evasion for her personal use of the same shelter she sold to clients.

All four defendants face a maximum of five years in prison on the conspiracy charge. Thompson and Wulstein also face a maximum of three years in prison on each count of assisting in the preparation of false tax returns, while Predmore faces an additional maximum of five years in prison on each count of tax evasion. Sentencing will be determined by a federal district court judge after consideration of federal sentencing guidelines and other statutory factors.