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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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