Malone Jr., J.
Petitioners, husband and wife, were employees of Revco Construction Corporation, which petitioner Candace Revere owned and petitioner Terrence Revere operated. As a result of an audit in 2003 of Revco's withholding tax returns, which revealed that Revco had made substantial payments to petitioners for which tax had not been withheld and which were not reported on Revco's W-2 forms or withholding tax returns, the Department of Taxation and Finance issued...
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