Phillip L. Parr and Barbara M. Parr v. United States of America, James David Emerson and Nancy M. Emerson v. United States

JOHN R. BROWN, Chief Judge:

Doctors Parr and Emerson seek refund of Federal Income Taxes paid on sums received from the University of Florida College of Medicine during the taxable year 1968. Taxpayers, surgical residents at that institution during that year, claim that amounts received up to $3,-600.00 were excludable from gross income as fellowship grants under § 117 of the Internal Revenue Code of 1954. 1 In the refund suit the Government moved for summary judgment at the close of Plaintiff’s case. Perhaps with some despair and certainly not with any real hope that this Millenium would ever…