Wijsman v. Commissioner
United States Tax Court
Held: That sec. 117(b)(2)(B), I.R.C. 1954, limits the exclusion from gross income of amounts received as a fellowship grant to 36 months of entitlement to such exclusion, whether claimed or not, and regulations sec. 1.117-2(b)(2) and (3) properly so interprets such section. Petitioner here has failed to negative 36 months of such entitlement prior to the year in issue.
1Opinion of the Court
Robert A. Wijsman and Gertrud Z. Wijsman, Petitioners v. Commissioner of Internal Revenue, Respondent
Wijsman v. Commissioner
Docket No. 4220-67
United States Tax Court
54 T.C. 1539; 1970 U.S. Tax Ct. LEXIS 90;
July 28, 1970, Filed
Decision will be entered for the respondent.
Held: That sec. 117(b)(2)(B), I.R.C. 1954, limits the exclusion from gross income of amounts received as a fellowship grant to 36 months of entitlement to such exclusion, whether claimed or not, and regulations sec. 1.117-2(b)(2) and (3) properly so interprets such section. Petitioner here has failed to negative 36 months of…
2Cases cited2 opinions
- Proskey v. CommissionerUnited States Tax Court · 1969
- Wijsman v. CommissionerUnited States Tax Court · 1970