Legal Opinion

Christman v. Commissioner

United States Tax Court

Decided May 30, 1989No. Docket No. 26748-83Unpublished

Petitioner-husband was a house staff physician with the Baylor College of Medicine graduate program in Houston, Texas, during 1979, and with the Kettering Medical Center residency program in Dayton, Ohio, during 1980. His car was damaged in a flood during 1979. In 1980, petitioners received substantial amounts of long-term capital gains from the sales of securities; also, they paid substantial amounts of interest in connection with these securities.

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Petitioner-husband was a house staff physician with the Baylor College of Medicine graduate program in Houston, Texas, during 1979, and with the Kettering Medical Center residency program in Dayton, Ohio, during 1980. His car was damaged in a flood during 1979. In 1980, petitioners received substantial amounts of long-term capital gains from the sales of securities; also, they paid substantial amounts of interest in connection with these securities. Held: (1) Payments to petitioner-husband are not excludable from income as scholarships or fellowship grants. Sec. 117(a), I.R.C. 1954. (2)…

1Opinion of the Court

KENNETH D. AND PAMELA S. CHRISTMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Christman v. Commissioner

Docket No. 26748-83.

United States Tax Court

T.C. Memo 1989-259; 1989 Tax Ct. Memo LEXIS 259; 57 T.C.M. (CCH) 538; T.C.M. (RIA) 89259;

May 30, 1989.

Petitioner-husband was a house staff physician with the Baylor College of Medicine graduate program in Houston, Texas, during 1979, and with the Kettering Medical Center residency program in Dayton, Ohio, during 1980. His car was damaged in a flood during 1979. In 1980, petitioners received substantial amounts of long-term capital…

2Cases cited23 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Bingler v. JohnsonSupreme Court of the United States · 1969
  4. Sanford v. CommissionerUnited States Tax Court · 1968
  5. William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969

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