Legal Opinion

Rockswold v. United States

District Court, D. Minnesota

Decided June 27, 1979No. Civ. 3-77-305, 3-77-306, 3-77-321PublishedCited by 9 opinions

1Opinion of the Court

DEVITT, Chief Judge.

In these cases, consolidated for trial, plaintiffs seek a refund of taxes paid on “stipends” they received while medical fellows and candidates for advanced medical degrees at the University of Minnesota. Plaintiffs claim the stipends qualify as scholarships under § 117 of the Internal Revenue Code, and thus are excludable from gross income. The government is of a contrary view, maintaining the stipends are taxable income because they represent compensation for services rendered. The case was tried to the court from April 2-5, 1979. For the reasons stated below, this court…

2Cases cited19 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. Reese v. CommissionerUnited States Tax Court · 1966
  3. Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
  4. Bonn v. CommissionerUnited States Tax Court · 1960
  5. Phillip L. Parr and Barbara M. Parr v. United States of America, James David Emerson and Nancy M. Emerson v. United StatesCourt of Appeals for the Fifth Circuit · 1972

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3Cited by9 opinions

  1. Gaylan L. And Mary H. Rockswold Thomas A. And Susan E. Christiansen Melvin A. And Rebecca L. Yarlott, Jr. v. United StatesCourt of Appeals for the Eighth Circuit · 1980
  2. Melvin A. Yarlott, Jr. And Rebecca L. Yarlott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1983
  3. Yarlott v. Comm'rUnited States Tax Court · 1982
  4. United States v. Mayo Foundation for Medical Education and ResearchDistrict Court, D. Minnesota · 2003
  5. Johnson v. United StatesDistrict Court, D. Minnesota · 1981

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