Fisher v. Commissioner
United States Tax Court
T, a resident physician in psychiatry at the Philadelphia Psychiatric Center, received payments from the Center totaling $ 7,415.37 during 1967. Of that amount, $ 4,503.87 was attributable to funds granted to the Center by the National Institute of Mental Health to be used to provide "trainee stipend awards" for young doctors engaged in psychiatric residency programs.
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T, a resident physician in psychiatry at the Philadelphia Psychiatric Center, received payments from the Center totaling $ 7,415.37 during 1967. Of that amount, $ 4,503.87 was attributable to funds granted to the Center by the National Institute of Mental Health to be used to provide "trainee stipend awards" for young doctors engaged in psychiatric residency programs. Held, T may not exclude any portion of the payments from his gross income as a scholarship or a fellowship grant. Sec. 117, I.R.C. 1954; sec. 1.117-4(c), Income Tax Regs.
1Opinion of the Court
OPINION
Naum, Judge:
Section 117(a)3 excludes from gross income any amount received “as a scholarship at an educational institution” or “as a'fellowship grant.” Section 117 (b) (2) limits the amount of the exclusion available to nondegree candidates “to an amount equal to $300 times the number of months for which the recipient received amounts under the scholarship or fellowship grant” during the taxable year. Although on his return petitioner claimed a $3,600 deduction attributable to the payments he received from the Center, he now claims that $3,600 should be excluded from his gross income…
2Cases cited20 opinions
- 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
- Bonn v. CommissionerUnited States Tax Court · 1960
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3Cited by44 opinions
- Dr. Hollis K. (Iii) and Patricia D. Leathers v. United States of America Dr. William F. And June B. Blankenship v. United StatesCourt of Appeals for the Eighth Circuit · 1972
- Adams v. CommissionerUnited States Tax Court · 1978
- Burstein v. United StatesUnited States Court of Claims · 1980
- Olick v. CommissionerUnited States Tax Court · 1979
- Yarlott v. Comm'rUnited States Tax Court · 1982
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