Legal Opinion

Brubakken v. Commissioner

United States Tax Court

Decided November 18, 1976No. Docket No. 3790-75PublishedCited by 35 opinions

P was a candidate for the Ph.D. degree in clinical psychology. All candidates for such degree were required to serve a 1-year clinical internship. From September 1971 to September 1972, P was a psychology intern at a State hospital; he received payments totaling $ 3,051.23 in 1971 and $ 9,200.77 in 1972. Held, such payments were compensation for services and did not constitute a scholarship or fellowship grant excludable under sec. 117, I.R.C. 1954.

1Opinion of the Court

Simpson, Judge:

The Commissioner determined deficiencies in the petitioner’s Federal income taxes in the amounts of $517 for 1971 and $1,941.68 for 1972. The sole issue for decision is whether payments received by the petitioner, a psychology intern, are excludable from gross income as a scholarship or fellowship grant under 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 petitioner, David M. Brubakken, resided in Madison, Wis., at the time of filing his petition herein. He filed timely Federal income…

2Cases cited16 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. Bonn v. CommissionerUnited States Tax Court · 1960
  5. Anderson v. CommissionerUnited States Tax Court · 1970

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

3Cited by35 opinions

  1. Olick v. CommissionerUnited States Tax Court · 1979
  2. Yarlott v. Comm'rUnited States Tax Court · 1982
  3. Bogdan v. CommissionerUnited States Tax Court · 1978
  4. Hales v. CommissionerUnited States Tax Court · 1978
  5. Homer v. CommissionerUnited States Tax Court · 1977

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

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