Peiss v. Commissioner
United States Tax Court
Petitioner, an associate professor of physiology, was awarded a grant by the Markle Foundation in 1953 (to continue over several years) to enable him to continue his research and training in continuance of an academic career.
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Petitioner, an associate professor of physiology, was awarded a grant by the Markle Foundation in 1953 (to continue over several years) to enable him to continue his research and training in continuance of an academic career. Held, the payments received by petitioner in 1956 under the grant qualify as a fellowship grant and are, therefore, excludable from income under section 117, I.R.C. 1954, subject to the limitation in subsection 117(b)(2)(B). Held, further, petitioner's partial use of his residence during 1956 to carry on some of his professional activities, such as research and…
1Opinion of the Court
Mulroney, Judge:
The respondent determined a deficiency in petitioners’ 1956 income tax in the amount of $1,219.45.
The issues are (1) whether all or any portion of $6,000 received by Clarence Peiss in 1956 from the John and Mary R. Markle Foundation, is includable in his gross income and (2) whether he is entitled to a deduction for the professional use of his house.
FINDINGS OP PACT
Some of the facts have been stipulated and they are found accordingly.
The John and Mary R. Markle Foundation was created in 1927 by John Markle with the stated purpose “to promote the advancement and diffusion of…
2Cases cited2 opinions
- Bachmura v. CommissionerUnited States Tax Court · 1959
- Stone v. CommissionerUnited States Tax Court · 1954
3Cited by22 opinions
- Sharon v. CommissionerUnited States Tax Court · 1976
- Montgomery v. CommissionerUnited States Tax Court · 1975
- Bieberdorf v. CommissionerUnited States Tax Court · 1973
- Brooks v. CommissionerUnited States Tax Court · 1968
- Carroll v. CommissionerUnited States Tax Court · 1973
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