Legal Opinion

Knapp v. Commissioner

United States Tax Court

Decided March 15, 1988No. Docket No. 20277-83Published

Tuition payments were made by P's employer, NYU Law School, on behalf of P's children directly to the educational institutions they attended. Held: These payments are not scholarships under sec. 117, I.R.C. 1954, and are taxable compensation to petitioner. Held, further, the Court does not have jurisdiction to enforce the fringe benefit moratorium.

1Opinion of the Court

Charles L. Knapp and Beverley E. Knapp, Petitioners v. Commissioner of Internal Revenue, Respondent

Knapp v. Commissioner

Docket No. 20277-83

United States Tax Court

90 T.C. 430; 1988 U.S. Tax Ct. LEXIS 30; 90 T.C. No. 30;

March 15, 1988; As amended April 4, 1988; As amended March 21, 1988 March 15, 1988, Filed

Decision will be entered under Rule 155.

Tuition payments were made by P's employer, NYU Law School, on behalf of P's children directly to the educational institutions they attended. Held: These payments are not scholarships under sec. 117, I.R.C. 1954, and are taxable compensation to…

Also in this document: Concurrence; Dissent · Swift; Dissent · Wells.

2Cases cited38 opinions

  1. Skidmore v. Swift & Co.Supreme Court of the United States · 1944
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Helvering v. TaylorSupreme Court of the United States · 1935
  4. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  5. Bingler v. JohnsonSupreme Court of the United States · 1969

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