For hiding millions of dollars worth of income from the Internal Revenue Service, a Cody businesswoman has been ordered to serve 15 months in federal prison and to pay $3.8 million in back taxes and interest.

Susan K. Patrick, who co-owned a prominent media brokerage firm and co-owns a Cody-based network of radio stations, received the sentence Tuesday in Baltimore. Patrick is being allowed to remain free on bond over the coming months, with orders to check into a Bureau of Prisons facility on June 19.

The crime dated back more than a decade, relating to fraudulent returns Patrick submitted for the 2012 to 2015 tax years. Through an investigation that stretched across seven-plus years, the IRS discovered that Patrick had omitted $10 million worth of income from her business filings, and, in turn, $9.5 million from her personal tax returns. The crime involved doctoring legitimate tax documents and lying to IRS investigators, prosecutors said.

“To be clear: this is not a case where a misguided individual buried their head in the sand and hoped the IRS wouldn’t notice some missing taxes,” Matthew Cofer and Thomas Koelbl of the Justice Department’s Tax Division wrote in a court filing. “This is a case of flagrant dishonesty, of shameless disregard for the law.”

They said the fraud allowed Patrick to avoid more than $2.5 million in taxes, though it was only a temporary reprieve. Not only is the 64-year-old liable for the back taxes, she also owes $1.3 million worth of interest on the decade-old debt, prompting U.S. District Judge George Russell III to order a total of $3,843,922 in restitution.

Prosecutors had recommended 24 months of prison time for the “especially serious” tax crime, while Patrick asked to be placed on probation or house arrest.

In a sentencing memo submitted by her defense attorney, Patrick said she “sincerely apologizes for her actions and is saddened by the effect that this had had on her community, family and friends.” Her attorney called the crime an outlier in “an otherwise respectable, charitable and law-abiding life.” 

Making millions

Susan Patrick and her husband, William “Larry” Patrick, brokered billions of dollars worth of radio and television broadcasting deals over the past few decades through their firm, Patrick Communications. They also have co-owned Legends Communications of Wyoming, which operates 26 radio stations and translators in northern Wyoming — including KODI, KTAG, KZMQ and KCGL of Big Horn Basin Media.

Susan Patrick told IRS agents that Legend Communications was hit hard by the recession and did poorly in 2012-2015, but Patrick Communications did well.

In 2013, court filings indicate the couple earned over $4.3 million and used Patrick Communications funds to purchase a $250,000 condo in Bozeman, take a $20,600 vacation to the British Virgin Islands and buy a Tesla vehicle. However, Susan Patrick later manipulated the couple’s tax returns to claim they’d lost $773,163 that year.

“There are millions of hardworking Americans who pay their taxes each year despite struggling to make ends meet,” prosecutors wrote. “[Susan] Patrick was not one of them.”

An accounting firm had accurately prepared income tax returns for the Patricks and their businesses from 2012 to 2014, but Susan Patrick never filed them, court records say. When the IRS inquired about the missing returns in 2016, Patrick deleted $10 million from Patrick Communications’ returns and $9.5 million from her and her husband’s, then backdated the forms to make it look like they’d filed on time.

However, the ruse didn’t fool the IRS, in part because she accidentally left a 2015 label on the form that represented it as having been filed in 2013.

As the investigation became criminal, Susan Patrick continued lying, court records say, first reasserting that the forms had been filed on time, then claiming the manipulated returns were drafts that she’d submitted on accident.

Eventually, however, Patrick admitted to the fraud and accepted responsibility, pleading guilty in August to a felony count of filing a false tax return.

Acting alone

Patrick has said her husband and business partners knew nothing of what she’d done, indicating she kept the crime a secret through the yearslong IRS investigation.

“I wish that I had made different choices back then,” Patrick wrote in a November letter to the court. “It likely would have caused the end of our companies and the end of my marriage, but perhaps that would have been for the best.”

Larry Patrick filed for divorce in December and has asked a judge to restrict his wife from selling any of their property, incurring any debts or otherwise changing the status quo while the case is pending. In a filing submitted by his attorney, Larry Patrick said he “had no involvement in [Susan Patrick’s] criminal conduct and only became aware of the charges and investigation into [her] conduct when it became public knowledge through various press releases.”

Larry Patrick added that he only recently learned of a $5.22 million the IRS placed on the couple's home in 2019.

The filing alleged Susan Patrick has “mismanag[ed] and misappropriat[ed] funds for her personal and professional use.”

She has denied the allegations, saying in a January filing that Larry continues to consult with her regularly and “relies on her for the continued successful management of the business.”

Repercussions

Patrick Communications dissolved shortly after Susan Patrick’s guilty plea, with Larry and another partner each forming their own, separate ventures.

Meanwhile, Larry Patrick said in his divorce case that the Federal Communications Commission has opened an investigation into Legend Communications, where there have been open signs of financial stress.

Since the start of 2023, records show Legend Communications and its affiliated business, Target Digital Solutions, have amassed $29,000 worth of liens from the State of Wyoming for failing to pay workers compensation premiums, unemployment taxes and sales taxes. 

Meanwhile, a former Big Horn Basin Media employee told Judge Russell that when she tried to cash her final paycheck in August, it came back as “not sufficient funds.”

“For someone who owes the government more than $2.5 million dollars, I’m sure my bouncing paycheck for $1,093.10 is insignificant; however, to me that is a lot of money,” Monique Brown wrote in a November letter to the judge, arguing it suggested a lack of true remorse on Patrick’s part.

Additionally, a Cody business, Nerd Nation I.T. Solutions and Repair, contends in a pending lawsuit that it’s owed nearly $120,000 for services it provided to Legend Communications. The company disputes the claims.

Unclear circumstances

In support of her request for probation, Susan Patrick said she’s tried to have a positive impact on the people she comes into contact with. Letters submitted to the court referenced her charitable efforts — including tens of thousands of dollars worth of donations to help build a new school in Kenya and fund scholarships at her alma mater, the University of Iowa. Patrick’s attorney, Michael March of Maryland, said her charitable contributions “are representative of who she is as a person: caring, loving and hard working.”

March’s memo and several submitted letters vaguely allude to “the circumstances that led to” the crime, but those circumstances were redacted from the public record, apparently due to privacy concerns. For example, Patrick’s brother wrote in a letter that he believed she had become “completely overwhelmed” during a “terrible time,” but it’s unclear from the redacted version what he was referring to.

In her own November letter, which was also partially redacted, Patrick wrote that she “was not making excuses for my actions, regardless of what was going on in my life at the time.”

“... I made very bad choices,” she wrote, “and I am prepared to accept the consequences of my actions.”

Judge Russell recommended that Patrick serve her prison time at a facility in West Virginia. After she completes the 15-month sentence, Patrick will serve a year of supervised release.