Legal Opinion

Yarlott v. Comm'r

United States Tax Court

Decided April 12, 1982No. Docket No. 4802-78Published

Petitioner was a medical fellow enrolled in the University of Minnesota Graduate School Surgery Program in health sciences from July 1971 until his completion of the program in June 1978. The Surgery Program, which takes 7 years to complete, merges approximately 4 to 5 years of clinical activities with approximately 2 to 3 years of an academic surgery course of study. This academic phase combines formal course work with research, writing, and thesis requirements.

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Petitioner was a medical fellow enrolled in the University of Minnesota Graduate School Surgery Program in health sciences from July 1971 until his completion of the program in June 1978. The Surgery Program, which takes 7 years to complete, merges approximately 4 to 5 years of clinical activities with approximately 2 to 3 years of an academic surgery course of study. This academic phase combines formal course work with research, writing, and thesis requirements. Completion of the program fulfills the requirements for a Ph. D. degree in surgery. During the taxable years 1974 and 1975,…

1Opinion of the Court

Melvin A. Yarlott, Jr., and Rebecca L. Yarlott, Petitioners v. Commissioner of Internal Revenue, Respondent

Yarlott v. Comm'r

Docket No. 4802-78

United States Tax Court

78 T.C. 585; 1982 U.S. Tax Ct. LEXIS 113; 78 T.C. No. 41;

April 12, 1982, Filed

Decision will be entered for the respondent.

Petitioner was a medical fellow enrolled in the University of Minnesota Graduate School Surgery Program in health sciences from July 1971 until his completion of the program in June 1978. The Surgery Program, which takes 7 years to complete, merges approximately 4 to 5 years of clinical activities with…

2Cases cited32 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Bingler v. JohnsonSupreme Court of the United States · 1969
  3. Reese v. CommissionerUnited States Tax Court · 1966
  4. Proskey v. CommissionerUnited States Tax Court · 1969
  5. Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963

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