During the time period at issue here, petitioners were the president and vice-president of Dane & Murphy, Inc. (hereinafter the company), a moving and storage company that declared bankruptcy in 1987. For the years 1985, 1986 and 1987, withholding tax returns were filed on behalf of the company, but the taxes were never remitted. Because of their corporate offices, petitioners were subject to penalties imposed in the amount of the taxes...
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