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Decided Aug. 13, 2009 Before Spain, J.P., Kane, Malone, Jr., Kavanagh and McCarthy, JJ. Proceeding pursuant to CPLR article 78 (initiated in this Court pursuant to Tax Law §2016) to review a determination of respondent Tax Appeals Tribunal which determined that petitioners were not entitled to a reduction in their individual liability as responsible persons on behalf of the corporation.

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