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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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