Legal Opinion

Adams v. Commissioner

United States Tax Court

Decided December 28, 1978No. Docket No. 7047-76Published

Petitioner, one of four interns in a 125-patient nonprofit osteopathic hospital having 100 staff physicians, during the first 6 months of 1973, received a stipend of $ 875 and a housing allowance of $ 150 per month.

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Petitioner, one of four interns in a 125-patient nonprofit osteopathic hospital having 100 staff physicians, during the first 6 months of 1973, received a stipend of $ 875 and a housing allowance of $ 150 per month. By a written contract, petitioner agreed to perform the duties assigned to him by the hospital, maintain standards of professional competence as determined by the hospital, and to refrain during his internship from engaging in any outside activities of a professional nature or any nonprofessional activities which would interfere with his effective performance of the contract.…

1Opinion of the Court

John E. Adams and Phyllis E. Adams, Petitioners v. Commissioner of Internal Revenue, Respondent

Adams v. Commissioner

Docket No. 7047-76

United States Tax Court

71 T.C. 477; 1978 U.S. Tax Ct. LEXIS 3;

December 28, 1978, Filed

Decision will be entered for the respondent.

Petitioner, one of four interns in a 125-patient nonprofit osteopathic hospital having 100 staff physicians, during the first 6 months of 1973, received a stipend of $ 875 and a housing allowance of $ 150 per month. By a written contract, petitioner agreed to perform the duties assigned to him by the hospital, maintain standards of…

Also in this document: Dissent.

2Cases cited34 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  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. Thomas W. Banks v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963

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