Adams v. Commissioner
United States Tax Court
Petitioner, one of four interns in a 125-patient nonprofit osteopathic hospital having 100 staff physicians, during the first 6 months of 1973, received a stipend of $ 875 and a housing allowance of $ 150 per month.
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Petitioner, one of four interns in a 125-patient nonprofit osteopathic hospital having 100 staff physicians, during the first 6 months of 1973, received a stipend of $ 875 and a housing allowance of $ 150 per month. By a written contract, petitioner agreed to perform the duties assigned to him by the hospital, maintain standards of professional competence as determined by the hospital, and to refrain during his internship from engaging in any outside activities of a professional nature or any nonprofessional activities which would interfere with his effective performance of the contract.…
1Opinion of the Court
Featherston, Jvudge:
The Commissioner determined a deficiency in Federal income tax against petitioners for the taxable year 1973 in the amount of $541. Due to concessions by the parties the issue for decision is whether certain amounts received by John E. Adams during the taxable year 1973 are excludable from gross income as a scholarship or fellowship grant pursuant to the provisions of section 117.1
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts, the supplemental stipulation of facts, and the exhibits attached thereto, are incorporated herein by this…
2Cases cited19 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Reese v. CommissionerUnited States Tax Court · 1966
- Proskey v. CommissionerUnited States Tax Court · 1969
- Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
- 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
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3Cited by32 opinions
- Olick v. CommissionerUnited States Tax Court · 1979
- Yarlott v. Comm'rUnited States Tax Court · 1982
- Palmer F. Meek and Martha A. Meek, His Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1979
- Iglesias v. CommissionerUnited States Tax Court · 1981
- Steven and Faith Field v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1982
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