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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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