Lisa B. Williams - Page 15

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          unaware or ignorant of the fact that the bonus amounts were not             
          included in the amounts reflected in the Forms W-2.                         
               Petitioner with respect to 1993 claims reliance on a                   
          commercial return preparer.  Petitioner also claims that during             
          1994 and 1995 she inquired of Mr. Sullivan as to why her bonuses            
          were not included on her Forms W-2 for those years.  She contends           
          that Mr. Sullivan advised her that the Form(s) W-2 was correct.             
          In that regard, petitioner may not avoid her duty to report                 
          accurately by placing the responsibility on an agent.  See United           
          States v. Boyle, 469 U.S. 241, 250-251 (1985).  More to the point           
          here, petitioner did not provide the preparer with information              
          about the payments from the corporation for the 1993 year, and              
          the preparer did not provide petitioner with legal or tax advice.           
          With respect to the 1994 and 1995 tax years, however, petitioner            
          admitted that she was aware that the amounts were not included on           
          the Forms W-2.  Irrespective of any advice that she may have                
          received from Mr. Sullivan, she was not entitled to rely on him             
          with respect to her income tax obligations.  Id.                            
               Under those circumstances, petitioner’s claim of reliance              
          upon the preparer or Mr. Sullivan was not reasonable, and                   
          petitioner is liable for the 20-percent penalty under section               
          6662(a) with respect to any underpayment that may result from the           
          failure to report the $25,000, $35,000, and $35,000 bonuses                 
          received during 1993, 1994, and 1995, respectively.  Betson v.              

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