Guido Ruggiero and Kristin Ruggiero - Page 2

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          of $290 in petitioners' 1991 Federal income tax.  On the basis of           
          petitioners' amended return, as well as arguments at trial, it is           
          clear that petitioners claim an overpayment in the amount of                
               After concessions,2 the issues for decision are:  (1) The              
          characterization of income and expenses relating to petitioner              
          Guido Ruggiero's (petitioner) activities during the taxable year            
          1991 and (2) the characterization of expenses incurred by                   
          petitioners in renting out their house during part of the year in           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time of filing the           
          petition, petitioner resided at Coral Gables, Florida, and                  
          petitioner Kristin Ruggiero resided at Cambridge, Massachusetts.            

          Tax Court Rules of Practice and Procedure.                                  
               2  Petitioners have conceded they are not entitled to deduct           
          travel expenses claimed in the amount of $3,732, and they are not           
          entitled to deduct claimed Schedule E expenses for repairs and              
          maintenance in the amount of $318 and depreciation in the amount            
          of $2,824, attributable to the rental use of their Connecticut              
               The parties further agree that net royalty income in the               
          amount of $236, received by petitioner Kristin Ruggiero, should             
          have been reported on Schedule E, rather than on Schedule C.                

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