A Cody businesswoman recently pleaded guilty to filing a false tax return, admitting she withheld and then manipulated several years of returns in an attempt to avoid paying more than $2.5 million in taxes.

As part of a plea deal with federal prosecutors, Susan K. Patrick acknowledged that she’d hidden $10 million of business income — and, in turn, $9.5 million of personal income — between 2012 and 2014.

Patrick is scheduled to be sentenced on Dec. 19 in U.S. District Court in Baltimore. Although she now makes her home on the South Fork, she was a Maryland resident at the time in question.

Prosecutors say Patrick could face up to three years of prison time on the felony count, but her actual sentence will hinge on federal sentencing guidelines, information presented at her sentencing and, ultimately, the presiding judge.

Patrick and her husband, Larry, are best known in Wyoming as the owners of 22 radio stations and a digital marketing business spread across the northern part of the state, including the Cody-based Big Horn Basin Media. Across the country, however, the Patricks are better known for brokering $8.5 billion worth of radio and television broadcasting deals through their firm, Patrick Communications; the criminal case is connected to the millions of dollars the couple earned from that firm.

Patrick’s husband has not been charged with any wrongdoing, nor has another partner in the business; Patrick says they knew nothing about what she did.

“I am sincerely sorry for the pain and embarrassment that this is causing my family, friends and business associates,” she said in a statement issued to media outlets last week.

Patrick called her actions “a very serious lapse of judgment a decade ago.”

“I am fully ready to be held accountable and to do whatever I can and need to do to make up for my decisions of the past,” she said in the statement.

Court records indicate the plea agreement had been in the works for some time: Patrick and her attorney signed off on the deal in March — almost five months before attorneys with the U.S. Department of Justice’s Tax Division filed the charge. She pleaded guilty at her initial Aug. 31 court appearance.

Doctored forms

A statement of facts attached to Patrick’s agreement says the trouble stemmed from her failure to submit tax returns for Patrick Communications and for her and her husband in 2012, 2013 and 2014. An accounting firm prepared all of the returns, the statement says, but Patrick never filed them.

When the IRS realized the forms were missing and made inquiries in June 2016, Patrick reportedly lied to the agency, claiming her accountants had already filed the documents. Patrick then mailed in what she said were copies.

“But these forms were not the tax returns that had been prepared by the defendant’s accounting firm,” says the statement of facts. “Instead of providing those accurate returns, the defendant doctored the tax returns prepared by her accountants to conceal income.”

The statement says Patrick edited Patrick Communications’ tax forms to remove $10 million worth of gross receipts and deleted more than $9.5 million worth of income from her and her husband’s own returns. In 2013, for example, Patrick reported that the couple had lost $773,163 when prosecutors say they actually made over $4.3 million.

To make it look like the doctored returns had been submitted on time, Patrick “falsely backdated her signature,” the statement says. Patrick also initially failed to file returns for tax year 2015.

The statement adds that “she committed these acts in order to evade paying the full amount of taxes she owed each year, and in fact ultimately evaded payment on an amount of tax due and owning of approximately $2,536,524.” Patrick signed the statement of facts on March 3, acknowledging it as “true and correct.”

The DOJ’s Tax Division announced her guilty plea in a news release issued not long after her Aug. 31 court appearance. As word spread among news outlets and trade publications, Patrick announced her resignation from Patrick Communications.

“To be clear, my partners in Patrick Communications, Larry Patrick and Greg Guy, were totally unaware of this,” Patrick said in her statement. “They continue to operate with the highest levels of integrity and expertise that you all have experienced from them in the past.”

The firm has been a major player in the broadcast industry since the 1980s, brokering more than 750 deals and consulting for dozens of broadcasters, cable companies and financial institutions. A 2019 report compiled by the Patricks and included in federal court records indicated that some of their work was billed at $800 an hour.

Susan Patrick’s biography said she’s personally brokered hundreds of millions of dollars worth of sales of broadcast and cable properties and has served on the National Association of Broadcasters Radio Board of Directors and the Federal Communications Commission’s Diversity Task Force.

Belated taxes

Court and other public records show the Patricks and their businesses have failed to pay taxes on time in the past.

Documents maintained by the Park County Clerk’s Office show the IRS filed $493,776 worth of liens against Legend Communications in late 2009 and early 2010. The liens — which related to unpaid taxes from 2008 and 2009 — appear to have been paid off, as they were fully released in the latter half of 2011.

Patrick’s criminal case also appears to have stemmed from unpaid taxes. Court records say the IRS was working to collect on Patrick Communications’ unfiled employment taxes when the agency realized that Patrick had also failed to file the corporate and personal income tax returns for 2012-2014.

While the criminal charge didn’t arrive until this year, records show the IRS filed a $5.22 million tax lien against the Patricks in 2019, relating to unpaid taxes from 2017. A database maintained by the Park County Clerk’s Office and accessed this week indicated that the lien remains in place.

Last month, meanwhile, the Wyoming Department of Workforce Services filed two liens against Legend Communications for nearly $14,200 worth of unemployment taxes and workers compensation premiums that the company reportedly failed to pay in the first quarter of 2023.

In her statement, Patrick said Legend Communications “is not related to this tax issue in any way.” She apologized “to the dedicated people at our radio stations across the state of Wyoming that do such a great job every day to serve their communities.”

The trade publication Communications Daily reported that a conviction could impact Patrick’s ability to hold the radio station’s licenses, quoting attorneys as saying that the FCC is “unlikely to overlook a broadcast owner pleading guilty to a felony.”