Di Bona v. Commissioner
United States Tax Court
Facts: Petitioner, a candidate for a Ph.D. degree, performed services under a teaching assistantship for which he received monthly payments from Iowa State University.
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Facts: Petitioner, a candidate for a Ph.D. degree, performed services under a teaching assistantship for which he received monthly payments from Iowa State University. He excluded these payments from his gross income as a scholarship or fellowship grant pursuant to section 117, I.R.C. 1954. Held: The amounts received by petitioner do not represent payments under a scholarship or fellowship grant since these payments were primarily for the purpose of compensating petitioner for services rendered rather than for the primary purpose of furthering his own education and training. Held, further: In…
1Opinion of the Court
Donald R. DiBona and Randi I. DiBona v. Commissioner.
Di Bona v. Commissioner
Docket No. 3563-66.
United States Tax Court
T.C. Memo 1968-214; 1968 Tax Ct. Memo LEXIS 86; 27 T.C.M. (CCH) 1055; T.C.M. (RIA) 68214;
September 24, 1968. Filed
Facts: Petitioner, a candidate for a Ph.D. degree, performed services under a teaching assistantship for which he received monthly payments from Iowa State University. He excluded these payments from his gross income as a scholarship or fellowship grant pursuant to section 117, I.R.C. 1954.
Held: The amounts received by petitioner do not represent payments under a…
2Cases cited6 opinions
- Reese v. CommissionerUnited States Tax Court · 1966
- Bonn v. CommissionerUnited States Tax Court · 1960
- Bhalla v. CommissionerUnited States Tax Court · 1960
- Paul j.ussery and Allean M. Ussery v. United StatesCourt of Appeals for the Fifth Circuit · 1961
- Evans v. CommissionerUnited States Tax Court · 1960
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