re is no change in either taxable income reported by the Taxpayers, or in the tax liability owed by the Taxpayers, for 2012, which was timely paid. The Original Return, the Amended Return and the accompanying International Information Returns were all prepared by the Taxpayers' professional accountants at Raich En

re is no change in either taxable income reported by the Taxpayers, or in the tax liability owed by the Taxpayers, for 2014, which was timely paid. The Original Return, the Amended Return and the accompanying International Information Returns were all prepared by the Taxpayers' professional accountants at Raich En