O'SCANNLAIN, Circuit Judge:
Wood appeals his conviction for tax evasion.
I
In December 1983, Wood established an entity known as the S-M-W Investment Group out of an office in Kalispell, Montana. At approximately the same time, Wood created entities known as Rover Resources and Norcross. Wood and his employees advertised these companies as Canadian mining exploration penny stocks that, if successfully promoted, would be listed and publicly traded...
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