Guido Ruggiero and Kristin Ruggiero - Page 10

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          respondent to have disallowed those claimed expenses as well.               
          Respondent determined that petitioner's expenses were incurred in           
          connection with his employment with UConn and, therefore, were              
          reportable as unreimbursed employee business expenses on Schedule           
          A.  As a result, respondent asserted that petitioner's                      
          alternative minimum tax liability was $6,655.                               
              In addition, respondent determined that petitioners                    
          overstated wage income on their original return in the amount of            
          $6,000.  In so doing, respondent asserted that the reader's fee             
          in the amount of $100 received from Emory University constituted            
          "other income", rather than wages.  Respondent also asserted that           
          the fellowship proceeds were not taxable to any extent because              
          petitioner remitted the fellowship proceeds to UConn in their               
          entirety.  Accordingly, respondent asserted that the entire                 
          amount which petitioner received from UConn, as reflected by the            
          Form W-2, constituted taxable wages which could not be offset by            
          any fellowship proceeds remitted by petitioner.                             
               Petitioners have since modified their position as indicated            
          on their original and amended returns.  Prior to trial,                     
          petitioners submitted a memorandum which summarized their present           
          position regarding items of income and expense pertaining to                
          petitioner's activities as follows:                                         
          Wage income from UConn                         $53,009                      
          Less:  Remittance to UConn                     (27,600)                     
          Total wages                                     25,409                      

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