Broniwitz v. Commissioner
United States Tax Court
Fellowship or scholarship grant: Degree candidate: Benefit of grantor: Primary purpose. - Held: Stipends paid to petitioner, a degree candidate, while he was a full-time student, directing his own courses of study, and not obligated to work for his grantor after receiving his degree were excludable under sec. 117, I.R.C. 1954, even though petitioner was required to work for grantor when not a full-time student and was nominally carried on grantor's rolls as an employee.
1Opinion of the Court
Laurence E. Broniwitz v. Commissioner.
Broniwitz v. Commissioner
Docket Nos. 6352-65, 1979-66.
United States Tax Court
T.C. Memo 1968-221; 1968 Tax Ct. Memo LEXIS 76; 27 T.C.M. (CCH) 1088; T.C.M. (RIA) 68221;
September 30, 1968. Filed
Fellowship or scholarship grant: Degree candidate: Benefit of grantor: Primary purpose. - Held: Stipends paid to petitioner, a degree candidate, while he was a full-time student, directing his own courses of study, and not obligated to work for his grantor after receiving his degree were excludable under sec. 117, I.R.C. 1954, even though petitioner was required to…
2Cases cited4 opinions
- Reese v. CommissionerUnited States Tax Court · 1966
- Bhalla v. CommissionerUnited States Tax Court · 1960
- Evans v. CommissionerUnited States Tax Court · 1960
- Johnson v. BinglerCourt of Appeals for the Third Circuit · 1968
3Cited by2 opinions
- Ehrhart v. CommissionerUnited States Tax Court · 1972
- Ehrhart v. CommissionerUnited States Tax Court · 1972