OPINION
HERLIHY, Judge.
The Director of the Division of Revenue [Director] has appealed a decision of the Tax Appeal Board [Board] reversing an assessment against Donald P. and Jane M. Stroup [Stroups], taxpayers. The assessment was for failure to file Delaware income tax returns for tax years 1980 and 1981. The Board found that the Stroups had filed in those years.
FACTS
On October 24, 1986, the...
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