- 6 -
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
University.
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
(continued...)
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