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petitioners argue that amounts paid to petitioner by UConn are
not wages insofar as they reflect a return of fellowship proceeds
previously remitted by petitioner.
Petitioners also argue that the fellowship proceeds which
petitioner received in the amount of $33,500 are fully taxable;
however, citing our opinion in Spiegelman v. Commissioner, 102
T.C. 394 (1994), petitioners contend that the fellowship proceeds
constitute neither wages nor earnings from self-employment.
Respondent determined that petitioner's wage income for the
taxable year 1991 totaled $53,009, the amount reflected on the
Form W-2 issued by UConn. Respondent maintains that petitioner
remitted all of the fellowship proceeds to UConn and,
consequently, argues that petitioners are neither required to
include the fellowship proceeds as income nor entitled to offset
the proceeds remitted to UConn from wages received from UConn.9
It is clear that the various positions taken by petitioners,
both on their amended return and at trial, were fashioned in an
attempt to reduce their liability under the alternative minimum
tax provisions. Petitioners' contentions that the fellowship
proceeds were fully taxable as noncompensatory income, and that
the remitted proceeds could offset gross wages paid by UConn, are
an attempt to buttress their argument, discussed infra, that
9 Respondent assumes a factual premise which is contrary to
the stipulated facts and evidence in the record. Therefore, we
shall disregard respondent's argument insofar as it relates to
the portion of the fellowship proceeds that was not remitted to
UConn.
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