Bailey v. Commissioner
United States Tax Court
P, a medical doctor, participated in a cardiorenal training program. All of P's activities were designed to train him in his individual capacity, and he performed no substantial services for the hospital or the laboratory. He had no responsibility for patient care, was never on call, and had no routine duties. Held, the stipend received by P during such training program was a fellowship grant under sec. 117, I.R.C. 1954.
1Opinion of the Court
George L. Bailey, Petitioner v. Commissioner of Internal Revenue, Respondent
Bailey v. Commissioner
Docket No. 643-72
United States Tax Court
60 T.C. 447; 1973 U.S. Tax Ct. LEXIS 106; 60 T.C. No. 48;
June 18, 1973, Filed
Decision will be entered for the petitioner.
P, a medical doctor, participated in a cardiorenal training program. All of P's activities were designed to train him in his individual capacity, and he performed no substantial services for the hospital or the laboratory. He had no responsibility for patient care, was never on call, and had no routine duties. Held, the stipend received…
2Cases cited22 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
- 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
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