Steiman v. Commissioner
United States Tax Court
Held, amounts of financial aid received by petitioners Robert Henry Steiman and Helen S. Lieberman during 1967 as graduate assistants while studying for doctoral degrees are excludable from income as scholarships or fellowship grants under sec. 117, I.R.C. 1954; the primary purpose of the payment of such amounts was to further their education and training rather than to compensate them for services rendered or to be rendered.
1Opinion of the Court
Feati-ieRSton, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax for 1967 as follows:
Docket No. Petitioner Deficiency
3714-70_Robert Henry Steiman_ $54. 00
3715-70_Stanley I. Lieberman and Helen S. Lieberman_ 728. 88
The only issue is whether the amounts received by the petitioners Robert Henry Steiman and Helen S. Lieberman as graduate assistants at Wayne State University while studying for doctor of philosophy degrees are excludable from income as scholarships or fellowships within the meaning of section 117.1
FINDINGS OF FACT
Petitioners Robert Henry Steiman…
2Cases cited5 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Reese v. CommissionerUnited States Tax Court · 1966
- Bhalla v. CommissionerUnited States Tax Court · 1960
- Jamieson v. CommissionerUnited States Tax Court · 1969
- Rodger Wyley, 3253 v. Warden, Maryland PenitentiaryCourt of Appeals for the Fourth Circuit · 1967
3Cited by51 opinions
- Weinberg v. CommissionerUnited States Tax Court · 1975
- Bailey v. CommissionerUnited States Tax Court · 1973
- Brubakken v. CommissionerUnited States Tax Court · 1976
- Adams v. CommissionerUnited States Tax Court · 1978
- Meehan v. CommissionerUnited States Tax Court · 1976
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