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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:
Income:
Wage income from UConn $53,009
Less: Remittance to UConn (27,600)
Total wages 25,409
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