The Tax Times: How Not to Handle an IRS Audit and Wind Up in Prison

Tuesday, September 5, 2023

How Not to Handle an IRS Audit and Wind Up in Prison

The case below indicates exactly how NOT to handle an IRS audit and the implications of such actions. According to Law360, an owner of a media brokerage firm agreed to pay $2.5 million in restitution for back taxes after admitting she failed to report $9.5 million in personal income and $10 million in gross receipts from her company, according to a plea filed in Maryland federal court in the case of U.S. v. Susan K. Patrick, case number 1:23-cr-00254-GLR, in the U.S. District Court for the District of Maryland.

Susan Patrick, who co-owns Patrick Communications with her husband, pled guilty to one count of filing a false individual tax return for 2013, reporting an income loss of $773,000 when the couple actually had earned $4.3 million that year, according to the plea agreement filed on August 31, 2023.

Patrick also admitted to lying to Internal Revenue Service agents who began investigating her company in 2016 for unfiled employment tax returns, according to the plea, which she signed in March.

During the collections investigation, the IRS discovered she and her husband had not filed corporate returns for 2012 through 2014. Patrick told the IRS that the couple had filed the returns on time and that the returns had been prepared by their accountants, according to the plea.

Patrick then sent the IRS doctored versions of the returns that had been accurately prepared by the accountants, but never filed by the couple, for the missing years, according to the plea. Patrick falsely reduced the couple's income by more than $9.5 million for the three years and hid $10 million in their company's gross receipts, according to the plea.
Patrick backdated her signature on the falsified returns to make it look as if she had signed them for on-time submission, according to the plea.
Additionally, Patrick never filed corporate or personal returns for 2015, despite her accountants having prepared them for her, according to the plea.

Ultimately, Patrick Avoided Paying $2.5 Million In
Taxes For 2012 Through 2015, Including
Nearly $1.5 Million Owed For 2013.

Patrick is one of three principals, including her husband, Larry Patrick, of the Maryland-based brokerage company, which also does investment banking, according to the company's website. The company sells radio and television stations and says it has negotiated or appraised media transactions valued at more than $8.5 billion in the last 25 years, including a $9.5 million recent acquisition from The Walt Disney Co.

Patrick is scheduled to be sentenced Dec. 19 in Baltimore and could face up to three (3) years in prison, according to court filings.

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