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Issue: I. Did Petitioners meet their burden of proving a change in their North Carolina domicile by showing: (1) an actual abandonment of the first domicile, coupled with an intention not to return to it; (2) the acquisition of a new domicile by actual residence at another place; and (3) the intent of making the newer residence a permanent home?
II. Did Petitioners meet their burden to show that the Department improperly imposed the large tax deficiency penalties?
III. Did the ALJ improperly abate interest on the assessments?