Court of Appeals for the Seventh Circuit November 5, 1990, 89-2451 (Gold Emporium, Inc., Michael J. Malicki and Kathleen Malicki v. Commissioner of Internal Revenue)

BAUER, Chief Judge.

Petitioners Gold Emporium, Inc. (“Gold Emporium”), Michael J. Malieki (“taxpayer” or “Malieki”) and Kathleen Malieki (referred to together with Michael Malieki as “the Malickis”) appeal the United States Tax Court’s decision upholding, in part, the Commissioner of Internal Revenue’s (“Commissioner”) tax deficiency assessment against them for unreported income during the tax