The U.S. Tax Court has "repeatedly confirmed that a Form 4340 can provide the basis for finding that a taxpayer has not filed a return." Wheeler v. Comm'r, 446 F. App'x 951, 953 (10th Cir. 2011) (citing Hazel v. Comm'r, 95 T.C.M. (CCH) 1528, 2008 WL 2095614, at *2-3 (2008) (collecting cases)). Accordingly, the IRS met its evidentiary burden.