- 18 - 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 engagedPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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