Legal Opinion

Carroll v. Commissioner

United States Tax Court

Decided April 23, 1973No. Docket Nos. 3127-71, 336-72PublishedCited by 13 opinions

P, a member of the faculty of U, was a principal investigator on two research projects supported by basic research grants by the National Science Foundation. During 2 months of the summers of 1965 and 1967, P worked full time on such projects and received payments out of the funds so granted equal to his regular rate of compensation during the academic year.

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P, a member of the faculty of U, was a principal investigator on two research projects supported by basic research grants by the National Science Foundation. During 2 months of the summers of 1965 and 1967, P worked full time on such projects and received payments out of the funds so granted equal to his regular rate of compensation during the academic year. Held, such payments received by P do not constitute a scholarship or fellowship grant excludable under sec. 117, I.R.C. 1954.

1Opinion of the Court

Simpson, Judge:

The respondent determined deficiencies in the petitioners’ Federal income taxes of $230.67 for 1965 and $265.85 for 1967. The issue for decision is whether payments received by a principal investigator in connection with research performed by him under a basic research grant by the National Science Foundation are excludable fellowship grants within the meaning of section 117 (a) of the Internal Revenue Code of 1954.1

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found.

The petitioners, Robert W. Carroll and Berenice A. Carroll, are husband and…

2Cases cited15 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. Reese v. CommissionerUnited States Tax Court · 1966
  3. Proskey v. CommissionerUnited States Tax Court · 1969
  4. Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
  5. Bonn v. CommissionerUnited States Tax Court · 1960

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

3Cited by13 opinions

  1. Weinberg v. CommissionerUnited States Tax Court · 1975
  2. Bailey v. CommissionerUnited States Tax Court · 1973
  3. Kammerer v. CommissionerUnited States Tax Court · 1976
  4. Bailey v. CommissionerUnited States Tax Court · 1973
  5. Carroll v. CommissionerUnited States Tax Court · 1973

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

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