A federal grand jury in Dallas indicted four Texans on September 22, 2026, alleging they promoted an illegal trust-based tax shelter that hid more than $1.5 billion in income and caused the IRS an estimated loss of more than $200 million.
The 24-count indictment names Duncan John MacDonald, Sarah Duren, Richard Ronald Cayce and Thomas Weickgenant. It charges conspiracy to defraud the United States and other offenses.
The Justice Department announced the charges on October 13, 2026, and publicized the indictment on October 14. The indictment is an allegation, and all four are presumed innocent unless prosecutors prove the charges beyond a reasonable doubt.
Prosecutors allege the scheme sold clients tax deferral through sham trusts. The indictment also accuses the promoters of concealing their own income, and alleges MacDonald diverted investor money to luxury purchases.
Clients allegedly kept control while trusts deferred taxes indefinitely
The defendants allegedly charged fees that often exceeded $100,000. They told clients they could transfer income to trusts and defer taxes “in perpetuity,” while retaining the benefit and control of their assets, according to the indictment.
Marketing materials pitched the arrangement as a way to “own nothing but control everything.” MacDonald operated Economic Strategist and other firms, prosecutors allege.
The indictment says some clients were urged to backdate trust documents and file amended income tax returns seeking refunds for earlier years. Lawyers warned clients about the arrangements. One wrote: “It remains my very strong recommendation to take steps to rectify the situation and to mitigate your criminal exposure.” Another wrote: “It's tax fraud and those provisions don't allow for free tax gains”
The allegations assign separate roles to the four defendants
Prosecutors describe MacDonald and Duren as common-law spouses who allegedly concealed his ownership of the shelter business and lied to federal investigators. The indictment also accuses them of filing false returns, hiding income through trusts and nominee accounts held by third parties, and paying personal expenses through those accounts. Prosecutors said they “held themselves out publicly as married.”
Cayce allegedly owned the distributorship that licensed the shelter and received millions in fees without reporting the income on his returns. Weickgenant allegedly prepared false returns for clients and obstructed IRS audits.
The indictment says Weickgenant told clients not to speak with the IRS and encouraged at least one client to defy a U.S. District Court order enforcing an IRS summons. He was booked into the Smith County Jail on October 11 on a courtesy hold for the IRS, then booked out on October 13.
MacDonald allegedly solicited $2 million from investors for shares in a business that purportedly would promote the shelter by developing digital trusts. Prosecutors say he instead bought a 2021 Rolls Royce Ghost and made a down payment on an Ocean Alexander 28E yacht. At the time, he was under a court-ordered injunction barring sales of securities not registered with the Securities and Exchange Commission.
The 24 counts carry different maximum prison terms
The indictment assigns charges and statutory maximum terms by count. Those maximums are not predictions of any sentence.
| Counts | Alleged offense | Defendant or defendants | Maximum prison term |
|---|---|---|---|
| 1 | Conspiracy to defraud the United States | All four | 5 years |
| 2–6 | Aiding in the preparation of a false return | MacDonald, Cayce and Weickgenant | 3 years per count |
| 7 | Corrupt interference with the IRS | Weickgenant | 3 years per count |
| 8–10 | Tax evasion | MacDonald | 5 years per count |
| 11–13 | Tax evasion | Duren | 5 years per count |
| 14–15 | Tax evasion | MacDonald and Duren | 5 years per count |
| 16–19 | Filing a false return | Cayce | 3 years per count |
| 20–21 | Wire fraud | MacDonald | 20 years per count |
| 22–24 | Transactions with criminally derived property | MacDonald | 10 years per count |
MacDonald and Duren pleaded not guilty in Dallas
Both appeared in Dallas federal court on October 14 and pleaded not guilty. A judge ordered MacDonald detained without bail after prosecutors argued he posed a “serious risk” of flight and obstruction.
Duren’s lawyer, James Whalen, said: “We anticipate that she is an innocent spouse and relied on the wisdom of her husband, maybe to her detriment.” He said the couple entered a common-law marriage after MacDonald’s release from prison.
U.S. Attorney Ryan R. Raybould for the Northern District of Texas said the defendants deprived the Treasury of more than $200 million. “The defendants orchestrated a sprawling, multimillion-dollar operation that encouraged wealthy clients to hide their income behind fraudulent trust structures, depriving the United States Treasury of more than $200 million in lawfully owed revenue.”
MacDonald pleaded guilty in 2013 in a healthcare fraud case and was sentenced to five years in prison. He was 50 years old at his 2014 sentencing. The Securities and Exchange Commission sued him in 2013; a judge entered a final judgment 10 years later ordering him to pay $8.8 million in restitution. The indictment also alleges he and Duren hired a firm to remove online material about his company and his prior fraud conviction.
Assistant Attorney General Colin M. McDonald and Raybould announced the case. IRS Criminal Investigation is investigating; Assistant U.S. Attorney Eric B. Chen and National Fraud Enforcement Division prosecutors are handling the prosecution.
The case was part of a six-week federal enforcement push
The Justice Department announced its first-ever National Tax Enforcement Surge on October 14, citing 76 defendants and more than $490 million in estimated intended tax losses. The cases included new charges against 31 individuals, and prosecutors also highlighted recent tax-fraud cases against more than 70 people.
Over approximately six weeks, 35 U.S. attorneys’ offices and IRS criminal investigators took part. The effort produced 23 new charging actions involving more than $350 million in alleged intended losses. Another 45 defendants faced trials, guilty pleas or sentencings associated with nearly $140 million in estimated intended losses.
Attorney General Todd Blanche said, “Every dollar stolen through tax fraud is a dollar taken from the American people. What we uncovered during this concentrated surge is only the tip of the iceberg. The Department of Justice is committed to expanding our investigations and exposing schemes designed to evade accountability, because there is no safe haven for fraudsters”
IRS Criminal Investigation chief Jarod Koopman described the effort as a new enforcement approach and said it “will not be the last.” The Justice Department established its National Fraud Enforcement Division in April.
Assistant Attorney General Colin McDonald said the department is building an asset forfeiture and recovery team to pursue property allegedly bought with fraud proceeds, including luxury vehicles and real estate. He gave no recovery total, saying some cases remained in early stages and investigators sometimes found proceeds already spent.
The Justice Department’s announcement of the charges identifies IRS Criminal Investigation as the investigating agency. The defendants remain presumed innocent unless prosecutors prove the charges beyond a reasonable doubt.
