Guido Ruggiero and Kristin Ruggiero - Page 7

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               On their return for the taxable year 1991, petitioners                 
          reported the following income, attributable to petitioner's                 
          professional activities, as wages:                                          
                                                                                     
          Payor                    Form Issued             Amount                     
          UConn                            W-2                 $ 53,009               
          Guggenheim                       1099                  27,000               
          Harvard                          1099                   6,500               
          Emory University1                unknown                   100              
          Total amount received                                  86,609               
          Less:  Fellowship proceeds                                                  
          paid to UConn                                       (27,600)                
          Reported as wages                                      59,009               
                                                                                     
               1  This amount was paid to petitioner as a "reader's fee".             

          Thus, despite the fact that the fellowships were reported by the            
          respective payors on Forms 1099, petitioners reported both of the           
          fellowships ($27,000 plus $6,500) as wage income and then                   
          deducted from wages $27,600, the amount remitted to UConn.  As a            
          result, and with the addition of the $100 "reader's fee",                   
          petitioners originally reported $6,000 more in wage income than             
          the amounts reflected on petitioner's Form W-2.                             
               Petitioners also claimed deductions on Schedule A in the               
          amount of $59,736, pertaining to unreimbursed employee business             
          expenses.  Of these expenses, $33,332 is attributable to                    

               6(...continued)                                                        
          constitute one-half of either of these amounts, we assume that              
          petitioner remitted the proper amount as required by the                    
          agreement.                                                                  




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