June 28, 2022

United States Attorney Alison J. Ramsdell announced that a Longmont, Colorado, man convicted of Impeding the Internal Revenue Service was sentenced on June 21, 2022, by U.S. District Judge Lawrence L. Piersol.

Loren Brown was sentenced to three years of probation, a $3,000 fine, and a special assessment to the Federal Crime Victims Fund in the amount of $100.

Brown was indicted by a federal grand jury on July 17, 2017. He pled guilty on August 10, 2020.

The conviction stemmed from incidents beginning in April of 2004 when Theodore Nelson and his son, Steven Nelson, created over 25 sham trusts to hide their income and assets from the Internal Revenue Service (IRS), thus evading the assessment and payment of federal income taxes. The Nelsons used forms created by Brown. The trusts were designed, in part, to make it difficult for the IRS to determine the Nelsons’ federal income tax liability. The Nelsons appointed John Sheridan and Loren Brown as trustees and successor trustees for the trusts until Sheridan’s death in 2011. In this manner, the Nelsons were able to put many layers between themselves and their assets/income. Brown’s agreement to act as successor trustee helped the Nelsons hide their income and assets from the IRS.

The Nelsons reside in Letcher, South Dakota. Loren Brown and his co-defendant, Randy L. Garriss, acted as signors for South Dakota bank accounts associated with Nelson trusts and performed most of their actions on behalf of the Nelsons’ tax evasion in South Dakota.

Among other acts, Brown and Garriss corruptly endeavored to obstruct and impede the due administration of the internal revenue laws by mailing to the IRS a Protest and Demand for Administrative Review on behalf of the Nelsons. Garriss signed on his own behalf and that of Brown as trustees for Steve Nelson and the Nelsons’ trusts. The letter was received by the IRS on January 5, 2016.

This case was investigated by IRS Criminal Investigation. Assistant U.S. Attorney Ann M. Hoffman prosecuted the case.