MEMORANDUM DECISION
WILLIAM F. STONE, JR., Bankruptcy Judge.
In 1998 the Defendant, the Internal Revenue Service, audited the Plaintiffs, Virgil and Mary Boddiford, for the tax years 1994, 1995, and 1996. The Service determined that the Boddifords improperly claimed deductions relating to the operation of a home office and asserted a civil fraud penalty for wilfulness. As an alternative to litigation, Mr. Boddiford and the IRS entered into a "closing...
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