Nelson M. Blohm and Joann M. Blohm v. Commissioner of Internal Revenue

DUBINA, Circuit Judge:

Appellants Nelson M. Blohm (“Blohm”) and JoAnn M. Blohm 1 appeal a judgment from the United States Tax Court upholding an Internal Revenue Service (“IRS” or the “Commissioner”) deficiency notice alleging that the appellants owed taxes on unreported income. We affirm.

I. FACTS

This tax deficiency case revolves around the nefarious business activities of Blohm and his business associates, Merlin C. Stick-elber (“Stickelber”) and Charles Ritchey (“Ritchey”). The facts are largely based upon the Tax Court’s detailed findings.

Blohm was president and chief operating officer of…