Guido Ruggiero and Kristin Ruggiero - Page 11

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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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