Hawronsky v. Commissioner
United States Tax Court
P received a tax-exempt scholarship from the Indian Health Services Scholarship Program (IHSSP) to attend medical school. IHSSP required P to sign a National Health Services Corp. (NHSC) scholarship program contract mandated by 42 U.S.C. secs. 241l and 254o (1988). Under the contract, P agreed to serve in the Indian Health Service for 4 years. P did not fulfill his service obligation. Instead, he began the practice of medicine at a private clinic.
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P received a tax-exempt scholarship from the Indian Health Services Scholarship Program (IHSSP) to attend medical school. IHSSP required P to sign a National Health Services Corp. (NHSC) scholarship program contract mandated by 42 U.S.C. secs. 241l and 254o (1988). Under the contract, P agreed to serve in the Indian Health Service for 4 years. P did not fulfill his service obligation. Instead, he began the practice of medicine at a private clinic. As a result, P was required by 42 U.S.C. sec. 254o(b)(1)(A) to pay treble damages to the Department of Health and Human Services (HHS). P deducted…
1Opinion of the Court
Colvin, Judge:
Respondent determined a $65,536 deficiency in petitioners’ Federal income tax for 1989. After concessions, the only issue for decision is whether petitioners may deduct amounts they paid to the Department of Health and Human Services (hhs) for breaching John W. Hawronsky’s (petitioner’s) obligation to serve for 4 years in the Indian Health Service after he accepted a scholarship from the Indian Health Services Scholarship Program (IHSSP). We hold that section 162(f) bars petitioners from deducting this payment.
Respondent alternatively contends that petitioners may not deduct any…
2Cases cited20 opinions
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Rendleman v. BowenCourt of Appeals for the Ninth Circuit · 1988
- United States v. Gary D. HatcherCourt of Appeals for the Ninth Circuit · 1991
- United States v. Brett Lawrence Arron, M.D.Court of Appeals for the Fifth Circuit · 1992
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3Cited by5 opinions
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- Stroud v. United StatesDistrict Court, D. South Carolina · 1995
- Hawronsky v. C.I.RCourt of Appeals for the Fifth Circuit · 1996
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- Hawronsky v. CommissionerUnited States Tax Court · 1995