Anderson v. Commissioner
United States Tax Court
Petitioner was an intern and a resident physician at Freedmen's Hospital, Washington, D.C., during the year in question, for which he received a stipend of $ 6,501.14. He claims the right to deduct $ 3,600 of the stipend as a fellowship grant under sec. 117(a)(1)(B), I.R.C. 1954, as amended.
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Petitioner was an intern and a resident physician at Freedmen's Hospital, Washington, D.C., during the year in question, for which he received a stipend of $ 6,501.14. He claims the right to deduct $ 3,600 of the stipend as a fellowship grant under sec. 117(a)(1)(B), I.R.C. 1954, as amended. Held, the stipend received by petitioner from Freedmen's Hospital in 1967 was not a "fellowship grant" within the meaning of sec. 117(a)(1)(B), and petitioner is not entitled to any deduction therefor. Aloysius J. Proskey, 51 T.C. 918 (1969), followed.
1Opinion of the Court
OPINION
Petitioner served the first half of 1967 as an intern and the second half of the year as a resident in internal medicine at Freedmen’s Hospital, Washington, D.C. It is his contention that $3,600 of the stipend that he received in that year is excludable as a fellowship grant under section 117(a) (1) (B). Respondent has determined that the stipend is fully taxable as compensation under section 61.
For the reasons discussed below, we sustain respondent’s determination in this case.
Section 117 provides, in the case of an individual, that gross income does not include any amount received as…
2Cases cited4 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Reese v. CommissionerUnited States Tax Court · 1966
- Proskey v. CommissionerUnited States Tax Court · 1969
- Bonn v. CommissionerUnited States Tax Court · 1960
3Cited by65 opinions
- Phillip L. Parr and Barbara M. Parr v. United States of America, James David Emerson and Nancy M. Emerson v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Weinberg v. CommissionerUnited States Tax Court · 1975
- Bailey v. CommissionerUnited States Tax Court · 1973
- Fisher v. CommissionerUnited States Tax Court · 1971
- Rosenthal v. CommissionerUnited States Tax Court · 1975
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