OPINION
G. ALAN WALDROP, Justice.
Appellants the State of Texas; the City of Houston, Texas; and the Transit Authority of Houston, Texas (collectively, the "State") sued appellees Steve Crawford and Robert Wills, as responsible individuals, for the sales tax liability of S.L. Crawford Construction, Inc. Seeking to establish appellees' individual liability under section 111.016(b) of the Texas Tax Code, the State asserted that Crawford and Wills willfully...
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