Bachmura v. Commissioner
United States Tax Court
Beginning in September of 1954, the taxable year herein, petitioner, the holder of a Ph. D. degree, was employed by Vanderbilt University at a salary of $ 4,600 per year. Pursuant to this employment, he devoted one-fourth of his working time to the teaching of classes in economics and the remaining three-fourths to work on a research project entitled "Southern Economic Development, with Particular Reference to Agriculture."
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Beginning in September of 1954, the taxable year herein, petitioner, the holder of a Ph. D. degree, was employed by Vanderbilt University at a salary of $ 4,600 per year. Pursuant to this employment, he devoted one-fourth of his working time to the teaching of classes in economics and the remaining three-fourths to work on a research project entitled "Southern Economic Development, with Particular Reference to Agriculture." The funds for the project were received by grant to Vanderbilt from the Rockefeller Foundation, for use over a period of 5 years beginning in 1952. The sources of…
1Opinion of the Court
opinion.
TURNER, Judge:
Prior to the enactment of the Internal Revenue Code of 1954, there was no statutory provision specifically covering the treatment, for income tax purposes, of amounts received as scholarships and fellowship grants. And in cases relating thereto, the question was whether the amounts so received were of such character as to fall within the statutory definition of gross income and the decisions usually turned on the conclusion as to whether the amounts represented compensation for services rendered, which did fall within the statutory definition of gross income, or were…
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- Brewster v. GageSupreme Court of the United States · 1930
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
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- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
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3Cited by30 opinions
- Reese v. CommissionerUnited States Tax Court · 1966
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- Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
- Bhalla v. CommissionerUnited States Tax Court · 1960
- Fisher v. CommissionerUnited States Tax Court · 1971
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