FILED 8 OC1 '1514:46lJSOC-(Wij> 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA, 

v. 

STEPHEN MILES MUNSON, 

Defendant. 

UNDER SEAL 

3:15-CR- 00 31.o4 - ~ 0 

INDICTMENT 

26 U.S.C. § 7206(1) and 

18 U.S.C. §§ 152(1) and (3) 

Forfeiture Allegation 

UNDER SEAL 

THE GRAND JURY CHARGES: 

GENERAL ALLEGATIONS 

At all times relevant to this indictment: 

1. Defendant Stephen Miles Munson (hereinafter defendant) was a resident of Bend, 

Oregon. Defendant is a retired U.S. Army Captain and has a bachelor's degree from the 

University of Oregon and two master's degrees, Master of Arts in Political Science and Master 

of Business Administration, from Stanford University. 

2. In 1991, defendant started Vulcan Power Company, a geothermal energy 

company in Bend, Oregon, and served in the company in different capacities, including president 

and chief executive officer, until 2008. 

3. In 2008, defendant sold a controlling interest in Vulcan Power Company for 

almost $15 million. 
4. On or about December 31, 2008, defendant sent the University of Oregon and 

Stanford University emails and letters, claiming to donate 200,000 shares of his former company 

to each school. The shares had an alleged value of $3 .2 million. 

5. On or about October 15, 2009, after obtaining an extension, defendant filed his 

2008 federal income tax return, claiming a $3.2 million credit for a charitable donation based on 

his alleged donation of shares of his former company to the University of Oregon and Stanford 

University. Due to his alleged donation, defendant requested and received a $407,019 refund 

from the Internal Revenue Service for that year. Defendant deposited the refund in his Wells 

Fargo checking account. 

6. Defendant never transferred any stock to the University of Oregon or Stanford 

University. 

7. In or about January 2011, defendant filed and caused to be filed a voluntary 

petition for bankruptcy in the District of Oregon, Case Number 11-30188. With his petition, 

defendant filed and caused to be filed a Statement of Financial Affairs and schedules of his assets 

and debts, declaring under penalties of perjury that his representations in these documents were 

true. In these documents, defendant purported to list all of his assets and liabilities and to 

provide additional material information concerning his assets and liabilities. 

8. During the pendency of his bankruptcy, defendant filed amended Statements of 

Financial Affairs and additional schedules and reports, declaring each time under penalties of 

perjury that his representations in these documents were true. In these documents, defendant 

purported to list his assets and liabilities and to provide additional material information 

concerning his assets and liabilities. 

Indictment Page 2 
9. Defendant's voluntary bankruptcy case, Case Number 11-30188, was eventually 

consolidated within an involuntary bankruptcy petition that former employees filed against 

defendant in or about October 2010 in an effort to compel defendant to pay them for past wages, 

Case Number 10-39795. 

10. Defendant filed his 2008 federal income tax return in support of his bankruptcy 

petition. Defendant omitted from his original bankruptcy filings almost $200,000 in assets, more 

than $200,000 in gifts, and more than $7 million in transfers to insiders and affiliates. During the 

pendency of his bankruptcy, defendant also failed to timely and properly report a state tax refund 

in the amount of $16,786. 

11. The Internal Revenue Service (IRS) is an agency of the United States Department 

of the Treasury and is responsible for administering and enforcing the tax laws of the United 

States and for collecting taxes owed to the United States Department of the Treasury. 

COUNT ONE 

(Filing False Federal Income Tax Return) 

(26 u.s.c. § 7206(1)) 

12. Paragraphs 1-11 of the General Allegations are incorporated herein. 

13. On or about October 15, 2009, in the District of Oregon, defendant did willfully 

make and subscribe a U.S. Individual Income Tax Return, Form 1040, for calendar year 2008, 

which was verified by a written declaration that it was made under the penalties of perjury, was 

prepared and signed in the District of Oregon, was filed with the IRS, and which defendant did 

not believe to be true and correct as to every material matter. On line 54, defendant claimed a 

$3 .2 million credit for alleged charitable donations based on purported donations of stock to the 

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Indictment Page3 
University of Oregon and Stanford University, whereas defendant then and there knew that no 

such donations of stock had been made. 

All in violation of26 U.S.C. § 7206(1). 

COUNT TWO 

(Bankruptcy Fraud - Concealment of Property) 

(18 u.s.c. § 152(1)) 

14. Paragraphs 1-11 of the General Allegations are incorporated herein. 

15. Between on or about January 11, 2011, and on or about October 21, 2013, in the 

District of Oregon, defendant did knowingly and fraudulently transfer and conceal and caused to 

be transferred and concealed from the trustee charged with control of the debtor's property, from 

creditors, and from the United States Trustee in connection with a case under Title 11, that is, In 

re Stephen Miles Munson, Case Numbers 10-39795 and 11-30188, property belonging to the 

estate of a debtor, to wit: fur coats and accessories, fishing equipment, musical instruments, 

trailers, a 2006 Vulcan motorcycle, a $50,000 deposit for the purchase of an airplane, horse 

equipment, horses, business interests, financial accounts, capital contributions, gifts, tax refunds, 

and cash. 

All in violation of 18 U.S.C. § 152(1). 

COUNT THREE 

(Bankruptcy Fraud - False Statement) 

(18 u.s.c. § 152(3)) 

16. Paragraphs 1-11 of the General Allegations are incorporated herein. 

17. On or about January 10, 2011, in the District of Oregon, defendant did knowingly 

and fraudulently make material false declarations, certificates, verifications, and statements, 

under penalty of perjury as permitted by 28 U.S.C. § 1746, in and in relation to his involuntary 

and voluntary petitions for bankruptcy, In re Stephen Miles Munson, Bankruptcy Case Numbers 

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10-39795 and 11-30188, by submitting and causing to be submitted a Statement of Financial 

Affairs and Schedules of Assets and Liabilities in which he knowingly and fraudulently omitted 

and caused to be omitted assets, income, transfers, gifts, capital contributions, business interests, 

personal property, and debt payments. 

All in violation of 18 U.S.C. § 152(3). 

COUNT FOUR 

(Bankruptcy Fraud - False Statement) 

(18 u.s.c. § 152(3)) 

18. Paragraphs 1-11 of the General Allegations are incorporated herein. 

19. Between on or about September 2, 2011, and on or about October 21, 2013, in the 

District of Oregon, defendant did knowingly and fraudulently make material false declarations, 

certificates, verifications, and statements, under penalty of perjury as permitted by 28 U.S.C. § 

1746, in and in relation to his involuntary and voluntary petitions for bankruptcy, Jn re Stephen 

Miles Munson, Bankruptcy Case Numbers 10-39795 and 11-30188, by submitting and causing to 

be submitted monthly operating reports in which he knowingly and fraudulently omitted a state 

tax refund in the amount of $16, 786. 

All in violation of 18 U.S.C. § 152(3). 

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FORFEITURE ALLEGATION 

(18 U.S.C. § 981(a)(l)(C) and 28 U.S.C. § 2461(c)) 

Upon conviction of one or more of the offenses alleged in Counts Two through Four of 

this indictment, defendant shall forfeit to the United States pursuant to 18 U.S.C. § 981 (a)(l )(C) 

and 28 U.S.C. § 2461(c), any property constituting or derived from proceeds obtained directly or 

indirectly as a result of said violations, including but not limited to a money judgment for a sum 

of money equal to the amount of property involved in Counts Two through Four. 

Dated this 

Presented by: 

BILLY J. WILLIAMS 

United States Attorney 

day of October 2015. 

D, OSB #062824 

Uni ed States Attorney 

Indictment 

A TRUE BILL 

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