Yarlott v. Comm'r
United States Tax Court
Petitioner was a medical fellow enrolled in the University of Minnesota Graduate School Surgery Program in health sciences from July 1971 until his completion of the program in June 1978. The Surgery Program, which takes 7 years to complete, merges approximately 4 to 5 years of clinical activities with approximately 2 to 3 years of an academic surgery course of study. This academic phase combines formal course work with research, writing, and thesis requirements.
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Petitioner was a medical fellow enrolled in the University of Minnesota Graduate School Surgery Program in health sciences from July 1971 until his completion of the program in June 1978. The Surgery Program, which takes 7 years to complete, merges approximately 4 to 5 years of clinical activities with approximately 2 to 3 years of an academic surgery course of study. This academic phase combines formal course work with research, writing, and thesis requirements. Completion of the program fulfills the requirements for a Ph. D. degree in surgery. During the taxable years 1974 and 1975,…
1Opinion of the Court
Sterrett, Judge:
By statutory notice dated March 6, 1978, respondent determined deficiencies in petitioners’ Federal income taxes for the taxable years 1974 and 1975 in the amounts of $4,189.47 and $4,839.76, respectively. The sole issue for decision is whether certain payments received by petitioner Melvin A. Yarlott, Jr., during the years in issue qualify for exclusion from gross income pursuant to section 117,1.R.C. 1954.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Pet…
2Cases cited31 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Reese v. CommissionerUnited States Tax Court · 1966
- Proskey v. CommissionerUnited States Tax Court · 1969
- Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
26 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Melvin A. Yarlott, Jr. And Rebecca L. Yarlott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1983
- Christman v. CommissionerUnited States Tax Court · 1989
- El Deeb v. CommissionerUnited States Tax Court · 1984
- Farmer v. CommissionerUnited States Tax Court · 1990
- Gomes v. CommissionerUnited States Tax Court · 1983
10 more not listed; retrieve them via the Exa API.