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assigned a portion of the proceeds to UConn. It is well settled
that a taxpayer cannot reduce gross income by executing an
anticipatory assignment of income earned by that taxpayer but not
yet received. Lucas v. Earl, 281 U.S. 111 (1930); Johnson v.
Commissioner, 78 T.C. 882 (1982), affd. without published opinion
734 F.2d 20 (9th Cir. 1984). On this basis, we reject
respondent's contention that the fellowship proceeds remitted to
UConn were not includible in gross income. We, therefore,
conclude that the full amount of the fellowship proceeds
($33,500) is includible in gross income. Nevertheless, pursuant
to our holding in Spiegelman v. Commissioner, supra, we hold that
the fellowship proceeds are noncompensatory and should be
characterized as "other income".
(b) Petitioner's Expenses
(1) Fellowship Proceeds Remitted to UConn
With respect to the fellowship proceeds remitted to UConn,
both parties have suggested that the remitted proceeds may be
used to offset petitioner's gross income. We have opined above
that the amounts received from UConn and the amount received as a
fellowship constitute gross income. In contrast to both parties'
position, however, we find that the remitted fellowship proceeds
constitute a deductible expense incurred as a condition of
receiving full salary from UConn. It is clear that petitioner
was required, pursuant to his employment with UConn, to pay over
a portion of the fellowship proceeds. Accordingly, we hold that
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