Wrobleski v. Bingler

JOHN L. MILLER, District Judge.

In this action, tried before the court without a jury, the plaintiff, a physician, seeks to recover an alleged overpayment of income tax for the calendar year 1956. The only question presented is whether an amount paid to the plaintiff in that year by the University of Pittsburgh constituted a fellowship grant excludable from gross income under Section 117 of the Internal Revenue Code of 1954, 26 U.S..C.A. § 117, subject to the limitations of .§ 117(b) (2), or whether that amount represented compensation for services taxable under applicable Regulations. The…