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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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