- 11 - 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 JanuaryPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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