Fielding v. Commissioner
United States Tax Court
After completing medical school and his internship petitioner entered into an agreement with the Department of Public Welfare of the State of Minnesota which provided him with educational allowances while he undertook a 3-year residency in psychiatry.
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After completing medical school and his internship petitioner entered into an agreement with the Department of Public Welfare of the State of Minnesota which provided him with educational allowances while he undertook a 3-year residency in psychiatry. In order to receive the allowances, petitioner had to promise the Department that he would enroll in an accredited residency program and that he would become an employee of the Department for a 2-year period following completion of his residency. Held, petitioner cannot exclude the allowances as a scholarship or fellowship under sec. 117. Held,…
1Opinion of the Court
Irwin, Judge:
Respondent determined the following deficiencies in the income taxes of petitioners:
Year Deflotency
1963 _ $466.40
1964 _ 1, 693.31
1965 _ 1. 572. 54
The deficiencies stem from respondent’s inclusion in gross income of amounts tliat petitioners excluded as a fellowship under section 117, and from respondent’s disallowance of deductions for tuition expense and his recomputation of petitioners’ medical expense deductions.
FINDINGS OF FACT
Some of the facts have been stipulated and they are found accordingly.
Leonard T. Fielding and Lois C. Fielding are husband and wife, who at the time of…
2Cases cited8 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Proskey v. CommissionerUnited States Tax Court · 1969
- Paul j.ussery and Allean M. Ussery v. United StatesCourt of Appeals for the Fifth Circuit · 1961
- Watson v. CommissionerUnited States Tax Court · 1959
- Evans v. CommissionerUnited States Tax Court · 1960
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Bailey v. CommissionerUnited States Tax Court · 1973
- Wassenaar v. CommissionerUnited States Tax Court · 1979
- Bergeron v. CommissionerUnited States Tax Court · 1972
- Bailey v. CommissionerUnited States Tax Court · 1973
- Emory v. CommissionerUnited States Tax Court · 1973
2 more not listed; retrieve them via the Exa API.