Ehrhart v. Commissioner
United States Tax Court
Held, "living allowances" paid by insurance companies to their actuarial employees attending the Northeastern University Graduate School of Actuarial Science were paid primarily for the benefit of the insurance companies and do not constitute scholarships or fellowships excludable from gross income of the recipients under sec. 117(a)(1), I.R.C. 1954.
1Opinion of the Court
The Commissioner determined deficiencies in petitioners’ income tax as follows:
Petitioners Petitioners
Year Ehrhart Tierney
1966___ $114,75_
1967_ 377.96 $344.03
1968_ 268.75 222.88
The only issue for decision is whether amounts received by petitioners Lawrence A. Ehrhart and Thomas P. Tierney, respectively, were ex-cludable from gross income as “scholarship [s]” or “fellowship grant[s] ” under section 117 (a) (1), I.E.C. 1951.
BINDINGS OF FACT
The parties have filed a stipulation of facts which, together with accompanying exhibits, is incorporated herein by this reference.
Lawrence A. and Melanie D.…
2Cases cited8 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Reese v. CommissionerUnited States Tax Court · 1966
- Proskey v. CommissionerUnited States Tax Court · 1969
- Turem v. CommissionerUnited States Tax Court · 1970
- MacDonald v. CommissionerUnited States Tax Court · 1969
3 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Bailey v. CommissionerUnited States Tax Court · 1973
- Brubakken v. CommissionerUnited States Tax Court · 1976
- Bieberdorf v. CommissionerUnited States Tax Court · 1973
- Lawrence A. Ehrhart v. Commissioner of Internal Revenue, Thomas P. Tierney v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1973
- Capital Blue Cross and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2005
16 more not listed; retrieve them via the Exa API.