Olick v. Commissioner
United States Tax Court
Petitioner-husband, a Native Alaskan, was engaged in the Alaska Rural Teacher Training Corps program, which involved classroom instruction and extensive practice teaching as a teacher's aide in native villages.
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Petitioner-husband, a Native Alaskan, was engaged in the Alaska Rural Teacher Training Corps program, which involved classroom instruction and extensive practice teaching as a teacher's aide in native villages. Held, the stipend he received under this program, on the facts, was excludable from petitioners' gross income as a scholarship under sec. 117, since the primary purpose of the practice teaching was to train petitioner-husband rather than to obtain his classroom assistance.
1Opinion of the Court
Hall, Judge:
Respondent determined a $588.58 deficiency in petitioners’ income tax for 1973, plus an addition to tax for negligence under section 6653(a)1 of $29.43. Due to a concession by respondent, the issues remaining for decision are:(1) Whether certain payments received in 1973 by Max D. Olick while he was a teacher-in-training in the Alaska Rural Teacher Training Corps program qualified as a scholarship excludable from gross income;(2) Whether petitioners’ underpayment of tax in 1973 was due to negligence; and(3) Whether petitioners are entitled to attorneys’ fees and costs.
FINDINGS OF…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Sharon v. CommissionerUnited States Tax Court · 1976
- Reese v. CommissionerUnited States Tax Court · 1966
- Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
15 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Estate of Crafts v. CommissionerUnited States Tax Court · 1980
- Allen v. CommissionerUnited States Tax Court · 1983
- Christman v. CommissionerUnited States Tax Court · 1989
- Daniel v. CommissionerUnited States Tax Court · 1980
- Estate of Crafts v. CommissionerUnited States Tax Court · 1980
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