Guido Ruggiero and Kristin Ruggiero - Page 18

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          Petitioners contend, therefore, the expenses related to his                 
          research and writing activities are deductible on Schedule C.               
               Petitioners' argument in this regard, in similar fashion to            
          their position concerning the characterization of the fellowship            
          proceeds, represents an attempt to reduce the effects of the                
          alternative minimum tax.  Work-related expenses incurred by an              
          independent contractor are deductible "above the line" (Schedule            
          C) under section 62(a)(1), whereas unreimbursed expenses incurred           
          by an employee are deductible "below the line" (Schedule A) as              
          itemized deductions.  Hathaway v. Commissioner, T.C. Memo. 1996-            
          389.  Section 56(b)(1)(A)(i) provides that, for the purposes of             
          calculating a taxpayer's alternative minimum taxable income, no             
          deductions shall be allowed for miscellaneous itemized                      
          deductions.  Therefore, were petitioner's expenses incurred as              
          part of a trade or business separate from his employment with               
          UConn, the expenses would be deductible "above the line" and                
          could be used to offset alternative minimum taxable income.  See            
          Kant v. Commissioner, T.C. Memo. 1997-217.                                  
               Petitioner's employment with UConn and receipt of a                    
          fellowship do not preclude the possibility that his research and            
          writing activities constituted a separate trade or business; it             
          is well settled that a taxpayer may engage in more than one trade           
          or business.  Gestrich v. Commissioner, 74 T.C. 525, 529 (1980),            
          affd. without published opinion 681 F.2d 805 (3d Cir. 1982);                
          Sherman v. Commissioner, 16 T.C. 332, 337 (1951).  To be engaged            

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