Isenbergh v. Commissioner
United States Tax Court
1. Held, that a Rockefeller Public Service Award received by petitioner is not excludible from gross income under section 74(b) of the Code of 1954. 2. Held, further, that portions of the Award paid as expenses incident to the carrying out of petitioner's plan of study under the Award, which respondent determined was a fellowship grant, are excludible from gross income under section 117(a)(2) of the Code of 1954. 3. Held, further, that petitioner has failed to prove error in…
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1. Held, that a Rockefeller Public Service Award received by petitioner is not excludible from gross income under section 74(b) of the Code of 1954. 2. Held, further, that portions of the Award paid as expenses incident to the carrying out of petitioner's plan of study under the Award, which respondent determined was a fellowship grant, are excludible from gross income under section 117(a)(2) of the Code of 1954. 3. Held, further, that petitioner has failed to prove error in respondent's determination of the value and useful life of certain household furnishings for the purpose of a claimed…
1Opinion of the Court
Fishee, Judge:
Respondent determined deficiencies in petitioners’ income tax for the calendar years 1954 and 1955 as follows:
Year Deficiency
1954_$2, 026.20
1955_ 1,271.25
Total_— 3,297.45
The issues presented for decision are (1) whether a Rockefeller Public Service Award is excludible in whole from gross income under section 74 (b) of the Code of 1954,1 but if not excludible in whole from gross income under section 74, whether certain portions paid out by petitioners as expenditures for travel, research, and clerical help are excludible from gross income as expenses incident to a fellowship…
2Cases cited6 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Untermyer v. AndersonSupreme Court of the United States · 1928
- Gaynor News Co. v. CommissionerUnited States Tax Court · 1954
- Antoinette M. Faraco v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- Solowey v. CommissionerUnited States Tax Court · 1950
1 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Casey v. CommissionerUnited States Tax Court · 1962
- Labay v. CommissionerUnited States Tax Court · 1970
- Malinowski v. CommissionerUnited States Tax Court · 1979
- Shedd v. CommissionerUnited States Tax Court · 1961
- William Simmons and Viola Simmons, His Wife v. United StatesCourt of Appeals for the Fourth Circuit · 1962
16 more not listed; retrieve them via the Exa API.