Guido Ruggiero and Kristin Ruggiero - Page 6

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          to 50 percent of his salary through the fellowship and grant                
          proceeds.  A letter dated December 11, 1995, written by Richard             
          Carterud, Assistant Controller for Grants and Contracts,                    
          University of Connecticut, described the arrangement as follows:            
               * * * [Petitioner] did have an option as to whether he                 
               wanted to remit his grant/fellowship to the University                 
               and stay on the University of Connecticut's payroll at                 
               100% of his academic salary or to keep the                             
               grant/fellowship's income and have his salary reduced                  
               to 50%.  His retirement program was enhanced by                        
               remitting his grant/fellowship income to the                           
               During the taxable year 1991, petitioner received payments             
          from UConn in the amount of $53,0095 and fellowship proceeds in             
          the amount of $33,500.  Petitioner's release from teaching duties           
          was in effect during this time.  Pursuant to his agreement,                 
          petitioner remitted $27,600 to UConn out of moneys paid to him              
          from Harvard and Guggenheim.  The fellowship proceeds were paid             
          into petitioner's personal bank account, and petitioner then                
          wrote checks from that account to UConn in an amount equal to               
          one-half of his salary.6                                                    

               5  All amounts are rounded to the nearest dollar.                      
               6  Although the stipulation of facts indicates that                    
          petitioner remitted proceeds to UConn in the amount of $27,500,             
          the record clearly indicates that the amount reimbursed was                 
          $27,600.  In such an instance, we are not bound by the                      
          stipulation of facts.  Jasionowski v. Commissioner, 66 T.C. 312,            
          318 (1976).  We also note that the Form W-2 issued by UConn                 
          reflects "Wages, tips, other compensation" in the amount of                 
          $53,009, and "Medicare wages and tips" in the amount of $55,799.            
          Although the amount remitted by petitioner does not precisely               

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