- 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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