Lisa B. Williams - Page 14

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               For 1994 and 1995, however, Mr. Williams prepared the joint            
          return, and petitioner admits that she was more careful with                
          respect to the reporting documents, including the Forms W-2.  She           
          noticed that the $35,000 amounts had not been included in the               
          Forms W-2.  Petitioner testified that she had asked Mr. Sullivan            
          about the absence of the bonus amounts from the Forms W-2, and              
          she contends that he said that her Forms W-2 were correct.  Mr.             
          Sullivan, however, denies any such conversation.  He remembers a            
          conversation about loans that had been made for the purpose of              
          paying Mr. Williams’s college tuition and whether forgiveness of            
          those loans was a taxable event for petitioner and Mr. Williams.            
          On that point, petitioner contends that the loans were not                  
          forgiven, but that she and Mr. Williams had repaid them in full.            
          Accordingly, the record is clouded as to any conversations                  
          between Mr. Sullivan and petitioner on the subject.                         
               Petitioner was aware of the $25,000 and the two $35,000                
          bonus payments received from her employer during 1993, 1994, and            
          1995.  She had discussions with Mr. Sullivan, who, as her                   
          immediate supervisor, rated her performance and recommended the             
          bonus amounts to Drs. Deland and Noell.  We note that                       
          petitioner’s base salary in 1993, 1994, and 1995 was in a range             
          of approximately $56,000 to $63,000.  Considering the fact that             
          her bonuses were nearly one-half or more than one-half of her               
          annual salary, it is highly unlikely that she could have been               

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