Case 2:21-cr-00724-JJT Document 1 Filed 09/07/21 Page 1 of 4

Fl£D _LODGED
1 GLENN B. McCORMICK - RECEIVED _ COPY
Acting United States Attorney
2 District of Arizona
SEP O7 2021
3 KEVIN M. RAPP
Assistant United States Attorney D4 SFTRAIRCT COURT
T i0 - IZONA
4 Arizona State Bar No. 014249
Two Renaissance Square DEPUTY
5 40 N. Central Ave. , Suite 1800
Phoenix, Arizona 85004
6 Telephone: 602-514-7500
Email: kevin.rapp@usdoj.gov
7 Attorneys for Plaintiff REDACiED FOR
PUBLIC DISCLOSUR!t
8
IN THE UNITED STATES DISTRICT COURT
9
FOR THE DISTRICT OF ARIZONA
10
11 United States of America, N 0. CR-21-00724-PHX-JJT (ESW)
12 Plaintiff,
INDICTMEN T
13 vs.
VIO: 26 U.S.C. § 7201
14 (Tax Evasion)
Ryan C. Patterson, Counts 1-3
15
Defendant.
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21 THE GRAND JURY CHARGES:
22 DEFENDANT
23 . 1. Defendant RYAN C. PATTERSON ("PATTERSON "), 33, resides in
24 Maricopa County, Arizona. PATTERSON owns and operates or operated a number of
25 construction or contracting businesses in the Phoenix area. PATTERSON' s businesses
26 offer services including flooring, restoration, remodeling, and plumbing. PATTERSON is
27 also involved in real estate investing, including buying properties, and building homes,
28 investing in existing homes, renovating, and reselling for a profit.
 Case 2:21-cr-00724-JJT Document 1 Filed 09/07/21 Page 2 of 4

1 COUNTl
2 2. From in or about January 2014 through in or about September 2015, in the
3 District of Arizona and elsewhere, PATTERSON, a resident of Scottsdale, AZ, willfully
4 attempted to evade and defeat income tax due and owing by him to the United States of
5 America, for the calendar year 2014, by preparing and causing to be prepared, and by
6 signing and causing to be signed, a false and fraudulent U.S. Individual Income Tax Return,
7 Form 1040, which was submitted to the Internal Revenue Service. On that tax return,
8 PATTERSON reported and caused to be reported that his taxable income for the calendar
9 year 2014 was $11,843 and that the amount of tax due and owing was $4,866. In fact,
10 during the calendar year 2014, PATTERSON underreported his taxable income by the
11 amount of $660,296, for total taxable income of $672,39. By underreporting his income,
12 PATTERSON caused an additional tax due and owing to the United States of America, in
13 the amount of $205,987.
14 3. PATTERSON did willfully attempt to evade and defeat the income tax by
15 due by committing affirmative acts of evasion, among others, by asking for and receiving
16 checks from clients in which his name, not a business name, was listed as the payee and
17 then deposited these checks into his personal bank accounts instead of his business bank
18 accounts.
19 In violation of Title 26, United States Code, Section 7201.
20
21 COUNT 2
22 4. From in or about January 2015 through in or about October 2016, in the
23 District of Arizona and elsewhere, PATTERSON, a resident of Scottsdale, AZ, willfully
24 attempted to evade and defeat income tax due and owing by him to the United States of
25 America, for the calendar year 2015, by preparing and causing to be prepared, and by
26 signing and causing to be signed, a false and fraudulent U.S. Individual Income Tax Return,
27 Form 1040, which was submitted to the Internal Revenue Service. On that tax return,
28 PATTERSON reported and caused to be reported that his taxable income for the calendar

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 Case 2:21-cr-00724-JJT Document 1 Filed 09/07/21 Page 3 of 4

1 year 2015 was $15,211 and that the amount of tax due and owing was $6,122. In fact,
2 during the calendar year 2015, PATTERSON underreported his taxable income by the
3 amount of $785,586, for total taxable income of $800,797. By underrep01iing his income,
4 PATTERSON caused an additional tax due and owing the United States of America, in the
5 amount of $304,341.
6 5. PATTERSON did willfully attempt to evade and defeat the income tax by
7 due by committing affirmative acts of evasion, among others, by asking for and receiving
8 checks from clients in which his name, not a business name, was listed as the payee and
9 then deposited these checks into his personal bank accounts instead of his business bank
10 accounts.
11 In violation of Title 26, United States Code, Section 7201.
12
13 COUNT 3
14 6. From in or about January 2016 through in or about October 2017, in the
15 District of Arizona and elsewhere, PATTERSON, a resident of Scottsdale, AZ, willfully
16 attempted to evade and defeat income tax due and owing by him to the United States of
17 America, for the calendar year 2016, by preparing and causing to be prepared, and by
18 signing and causing to be signed, a false and fraudulent U.S. Individual Income Tax Return,
19 Form 1040, which was submitted to the Internal Revenue Service. On that tax return,
20 PATTERSON reported and caused to be reported that his taxable income for the calendar
21 year 2016 was $0 and that the amount of tax due and owing was $2,116. In fact, during the
22 calendar year 2016, PATTERSON underrep01ied his taxable income by the amount of
23 $765,610, for total taxable income of $719,278. By underreporting his income,
24 PATTERSON caused an additional tax due and owing the united Sets of America, in the
25 amount of $272,601.
26 7. PATTERSON did willfully attempt to evade and defeat the income tax by
27 due by committing affirmative acts of evasion, among others, by asking for and receiving
28 checks from clients in which his name, not a business name, was listed as the payee and

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 Case 2:21-cr-00724-JJT Document 1 Filed 09/07/21 Page 4 of 4

1 then deposited these checks into his personal bank accounts instead of his business bank
2 accounts.
3 In violation of Title 26, United States Code, Section 7201.
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A TRUE BILL
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s/
7 FOREPERSON OF THE GRAND JURY
Date: September 7, 2021
8
GLENN B. McCORMICK
9 Acting United States Attorney
District of Arizona
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s/
12 KEVIN M. RAPP
Assistant U.S. Attorney
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