Legal Opinion

Ward v. Commissioner

United States Tax Court

Decided November 17, 1970No. Docket No. 4050-68PublishedCited by 16 opinions

Although employed as a welfare field representative by the Minnesota Department of Public Welfare, petitioner lacked the desirable qualification of a master's degree. Under Minnesota's federally assisted employee education program, petitioner applied for and received a 2-year "scholarship."

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Although employed as a welfare field representative by the Minnesota Department of Public Welfare, petitioner lacked the desirable qualification of a master's degree. Under Minnesota's federally assisted employee education program, petitioner applied for and received a 2-year "scholarship." Petitioner and the department entered into contracts whereby the department agreed to provide tuition plus two-thirds of petitioner's former salary during 2 academic years, and petitioner agreed to return to the department for at least a 2-year period after receiving his degree, or to repay the money…

1Opinion of the Court

DawsoN, Judge:

Respondent determined the following Federal income tax deficiencies against the petitioners:

Taxable year Deficiency

1964 ___. $370. 54

1965 _ 242. 30

1966 _ 251. 76

The only issue presented for decision is whether amounts received by petitioner Lowell D. Ward from the Minnesota Department of Public Welfare constituted a scholarship or fellowship grant excludable from his gross income under section 117.1

KINDINGS OK PACT

Some of the facts have been stipulated by the parties and are found accordingly.

Lowell D. and Suzanne M. Ward are husband and wife who at the time of filing their…

2Cases cited6 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. Reese v. CommissionerUnited States Tax Court · 1966
  3. Paul j.ussery and Allean M. Ussery v. United StatesCourt of Appeals for the Fifth Circuit · 1961
  4. Turem v. CommissionerUnited States Tax Court · 1970
  5. Evans v. CommissionerUnited States Tax Court · 1960

1 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. Bailey v. CommissionerUnited States Tax Court · 1973
  2. Willie v. CommissionerUnited States Tax Court · 1971
  3. Lowell D. Ward and Suzanne M. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1971
  4. Fielding v. CommissionerUnited States Tax Court · 1972
  5. Weiner v. CommissionerUnited States Tax Court · 1975

11 more not listed; retrieve them via the Exa API.

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