Kane, J.
The Department of Taxation and Finance (hereinafter Department) issued petitioners a notice and demand for payment of tax covering their 1995 personal income tax, interest and penalties. Petitioners claimed they sent a check with their tax return. The Department advised petitioners to submit documentation demonstrating that payment was made. Petitioners submitted a photocopy of the front of one check, but the back of another check. Petitioners eventually...
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