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Other income: Fellowship proceeds1 33,500
Expenses: Schedule C
Gross receipts: Reader's fee 100
Less: Petitioner's fellowship expenses 2(29,600)
Total Schedule C loss (29,500)
In comparison, respondent's present position is as follows:
Income:
Wage income from UConn $53,009
Less: fellowship proceeds remitted -0-
Total wages 53,009
Other income
Fellowship proceeds -0-
Reader's fee 100
Total other income 100
Expenses: Schedule A $29,600
1 Petitioners classify the fellowship proceeds as "other
income" because they maintain that the proceeds are neither wages
nor income from self-employment. See Spiegelman v. Commissioner,
102 T.C. 394, 406 (1994) (holding that fellowship proceeds were
not paid in consideration for services rendered).
2 Although petitioners' summary reflects expenses claimed in
the amount of $56,004, it is clear that this amount erroneously
includes expenses attributable to petitioner Kristin Ruggiero in
the amount of $26,404. The difference between $59,736, the
expenses claimed on the original return, and $3,732, the expenses
which petitioners have conceded are not allowable, would leave
$56,004. Of the expenses claimed on the original return, $26,404
is attributable to Kristin Ruggiero. Thus, the amount claimed is
$29,600 ($56,004 less $26,404).
2. Rental of Petitioners' Connecticut House
During the taxable year 1991, petitioners owned a house in
Hampton, Connecticut. Petitioner did not reside in the house at
any time during 1991, while petitioner Kristin Ruggiero resided
in the house from September to December 1991. From January
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