Jamieson v. Commissioner
United States Tax Court
Petitioner, a candidate for a Ph. D. degree in French, was paid $ 1,111.12 by the University of Texas in her capacity as a teaching assistant. Held, that the payments do not qualify as excludable fellowship grants under sec. 117, I.R.C. 1954, but are taxable as compensation for services rendered.
1Opinion of the Court
Dawson, Judge:
Respondent determined a deficiency of $222.43 in petitioners’ Federal income tax for the year 1964. The only issue for decision is whether amounts received by petitioner Suzanne M. Jamieson from the University of Texas are excludable from her gross income under section 117, I.R.C. 1954.1
FINDINGS OF FACT
Some of the facts were stipulated and are found accordingly.
Edward A. Jamieson and Suzanne M. Jamieson (herein referred to as petitioner), husband and wife filed their joint Federal income tax return for the calendar year 1964 with the district director of internal revenue at…
2Cases cited2 opinions
- Reese v. CommissionerUnited States Tax Court · 1966
- Johnson v. BinglerCourt of Appeals for the Third Circuit · 1968
3Cited by35 opinions
- Proskey v. CommissionerUnited States Tax Court · 1969
- Weinberg v. CommissionerUnited States Tax Court · 1975
- Steiman v. CommissionerUnited States Tax Court · 1971
- Bailey v. CommissionerUnited States Tax Court · 1973
- Meehan v. CommissionerUnited States Tax Court · 1976
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