Legal Opinion

Michael Cooney, M.D. And Karen Cooney v. The United States of America

Court of Appeals for the Sixth Circuit

Decided August 12, 1980No. 78-3469PublishedCited by 4 opinions

1Opinion of the Court

ENGEL, Circuit Judge.

Dr. Michael Cooney appeals from a judgment of the district court denying him relief in his suit for a refund of 1971 personal income taxes in the amount of $754.36.

The sole issue in this appeal is whether certain payments received by Dr. Cooney during his resident internship at the Mt. Carmel Hospital in Columbus, Ohio, were excludable from gross income as a fellowship grant or scholarship within the meaning of section 117 of the Internal Revenue Code of 1954. 1 The district court determined that the amounts received did not qualify as a fellowship grant or scholarship…

2Cases cited7 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. 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
  3. Eugene E. Hembree, Jr., and Belle D. Hembree v. United StatesCourt of Appeals for the Fourth Circuit · 1972
  4. Bhalla v. CommissionerUnited States Tax Court · 1960
  5. Betty Jane Stewart v. United StatesCourt of Appeals for the Sixth Circuit · 1966

2 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Steven and Faith Field v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1982
  2. Christman v. CommissionerUnited States Tax Court · 1989
  3. Perry v. CommissionerUnited States Tax Court · 1981
  4. Taylor v. CommissionerUnited States Tax Court · 1982

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