Legal Opinion

Wijsman v. Commissioner

United States Tax Court

Decided July 28, 1970No. Docket No. 4220-67Published

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

  1. Proskey v. CommissionerUnited States Tax Court · 1969
  2. Wijsman v. CommissionerUnited States Tax Court · 1970

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