Ti Li Loo v. Commissioner
United States Tax Court
Sec. 22 (a), I. R. C. -- Payments for Research -- Income. -- The University of Maryland received funds from the National Institutes of Health of the United States Public Health Service for carrying on research. The University of Maryland appointed the petitioner to a research fellowship for 1 year in 1947 and renewed the appointment each year until the fellowship was terminated in 1951. Before receiving the fellowship, petitioner received a Ph.
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Sec. 22 (a), I. R. C. -- Payments for Research -- Income. -- The University of Maryland received funds from the National Institutes of Health of the United States Public Health Service for carrying on research. The University of Maryland appointed the petitioner to a research fellowship for 1 year in 1947 and renewed the appointment each year until the fellowship was terminated in 1951. Before receiving the fellowship, petitioner received a Ph. D. degree from Oxford University in England. Under the University of Maryland fellowship, petitioner was assigned to do research work under the…
1Opinion of the Court
OPINION.
Haeeon, Judge:
The petitioner contends that the sum of $4,500 which he received in 1950 under a research fellowship is exempt from Federal income tax under the provisions of section 22 (b) (3) of the Internal Revenue Code. He contends, in general, that the fellowship was for the purpose of furthering his training and education. He relies strongly upon the point that he was classified as a “student” when he entered the United States in 1947, and that his status under the immigration statutes and regulations continued to be that of a student until some time in 1951 when he exercised the…
2Cases cited5 opinions
- Banks v. CommissionerUnited States Tax Court · 1952
- McDermott v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1945
- United States v. RobertsonCourt of Appeals for the Tenth Circuit · 1951
- Stein v. CommissionerUnited States Tax Court · 1950
- McDermott v. CommissionerUnited States Tax Court · 1944
3Cited by14 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Bachmura v. CommissionerUnited States Tax Court · 1959
- Stone v. CommissionerUnited States Tax Court · 1954
- Spiegelman v. CommissionerUnited States Tax Court · 1994
- Steinmetz v. United StatesDistrict Court, N.D. California · 1972
9 more not listed; retrieve them via the Exa API.