Bailey v. Commissioner
United States Tax Court
P, a medical doctor, participated in a cardiorenal training program. All of P's activities were designed to train him in his individual capacity, and he performed no substantial services for the hospital or the laboratory. He had no responsibility for patient care, was never on call, and had no routine duties. Held, the stipend received by P during such training program was a fellowship grant under sec. 117, I.R.C. 1954.
1Opinion of the Court
SimpsoN, Judge:
The respondent determined a deficiency of $783.85 in the petitioner’s Federal income tax for the year 1967. The sole issue for decision is whether a training stipend received by the petitioner is a fellowship grant under section 117(a) of the Internal Revenue Code of 1954.1
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioner, George L. Bailey, was a resident of Brookline, Mass., at the time his petition was filed in this case. He filed his Federal income tax return for the year 1967 with the district director of internal revenue,…
2Cases cited21 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Reese v. CommissionerUnited States Tax Court · 1966
- Proskey v. CommissionerUnited States Tax Court · 1969
- Bonn v. CommissionerUnited States Tax Court · 1960
- Phillip L. Parr and Barbara M. Parr v. United States of America, James David Emerson and Nancy M. Emerson v. United StatesCourt of Appeals for the Fifth Circuit · 1972
16 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- Weinberg v. CommissionerUnited States Tax Court · 1975
- Dietz v. CommissionerUnited States Tax Court · 1974
- Brubakken v. CommissionerUnited States Tax Court · 1976
- Meehan v. CommissionerUnited States Tax Court · 1976
- Gaylan L. And Mary H. Rockswold Thomas A. And Susan E. Christiansen Melvin A. And Rebecca L. Yarlott, Jr. v. United StatesCourt of Appeals for the Eighth Circuit · 1980
41 more not listed; retrieve them via the Exa API.