Guido Ruggiero and Kristin Ruggiero - Page 8

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          petitioner's activities, while the remaining expenses in the                
          amount of $26,404 are attributable to petitioner Kristin                    
          Ruggiero.  In addition, petitioners attached to their return an             
          alternative minimum tax computation which calculated an                     
          alternative minimum tax liability in the amount of $5,812.7                 
               On August 12, 1992, petitioners submitted to respondent an             
          amended return (Form 1040X).  Attached to the amended return was            
          a Schedule C which indicated "professor" as petitioner's                    
          profession.  The Schedule C reflects gross receipts in the amount           
          of $33,600, attributable to amounts petitioner received pursuant            
          to the two fellowships, as well as a "reader's fee" from Emory              
          University in the amount of $100.  These amounts had been                   
          reported as wages on the original return, and petitioners                   
          accordingly reduced the amount of wages reported on the amended             
          return.  Consistent with the original return, however, the amount           
          reported as wages on the amended return reflects total amounts              
          indicated on the Form W-2 issued by UConn, reduced by the                   
          fellowship proceeds which petitioner remitted to UConn.                     

               7  The notice of deficiency indicates that the alternative             
          minimum tax computation "per return" is $6,537.  We assume that             
          respondent made other mathematical adjustments to the alternative           
          minimum tax which are not reflected in the record.  In addition,            
          despite petitioners' attachment of an alternative minimum tax               
          computation to their return, petitioners' return does not reflect           
          that alternative minimum tax computation as "Other Taxes".  Since           
          this adjustment is not reflected in the notice of deficiency, we            
          further assume that respondent adjusted this item as a                      
          mathematical correction.  Sec. 6213(b)(1).                                  

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