MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
The issues for decision are whether respondent obtained verification of Federal income tax assessments and whether petitioners are liable for a section 6673(a)(1) penalty. All section references are to the Internal Revenue Code as amended.
FINDINGS OF FACT
When the petition was filed, petitioners resided in Goliad, Texas. On December 11, 1997, respondent issued a notice of deficiency...
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