Bergeron v. Commissioner
United States Tax Court
(1) The petitioners, psychiatric residents, received stipends from the State Department of Hospitals during the period of their training. The stipends were granted on condition that the recipients perform 2 years of service for the department after completion of their training.
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(1) The petitioners, psychiatric residents, received stipends from the State Department of Hospitals during the period of their training. The stipends were granted on condition that the recipients perform 2 years of service for the department after completion of their training. Held, the stipends are not excludable scholarships or fellowship grants under sec. 117(a), I.R.C. 1954. (2) During the training period, two of the petitioners received additional grants which the respondent treated as excludable under sec. 117(a). Held, the petitioners were not candidates for a degree within the…
1Opinion of the Court
RICHARD F. BERGERON, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bergeron v. Commissioner
Docket Nos. 3402-69, 3403-69, 3623-71.
United States Tax Court
T.C. Memo 1972-248; 1972 Tax Ct. Memo LEXIS 9; 31 T.C.M. (CCH) 1226; T.C.M. (RIA) 72248;
December 20, 1972, Filed(1) The petitioners, psychiatric residents, received stipends from the State Department of Hospitals during the period of their training. The stipends were granted on condition that the recipients perform 2 years of service for the department after completion of their training. Held, the stipends are not…
2Cases cited11 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Proskey v. CommissionerUnited States Tax Court · 1969
- Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
- Bonn v. CommissionerUnited States Tax Court · 1960
- Eugene E. Hembree, Jr., and Belle D. Hembree v. United StatesCourt of Appeals for the Fourth Circuit · 1972
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3Cited by1 opinion
- Batson v. CommissionerUnited States Tax Court · 1977