Bingler v. Johnson

We are called upon in this case to examine for the first time § 117 of the Internal Revenue Code of 1954, which excludes from a taxpayer’s gross income amounts received as “scholarships” and “fellowships.” The question before us concerns the tax treatment of payments received by the respondents 1 from their employer, the Westinghouse Electric Corporation, while they were on “educational leave” from their jobs with Westinghouse.

During the period here in question the respondents held engineering positions at the Bettis Atomic Power Laboratory in Pittsburgh, Pennsylvania, which Westinghouse…