Haley v. Commissioner
United States Tax Court
Petitioner was an employee of the Jackson County Public Welfare Commission of the State of Oregon. The petitioner was granted educational leave in 1964 and 1965 in order to attend the University of Washington, School of Social Work. Held, amounts received by the petitioner from the Oregon State Welfare Commission while on educational leave are not excludable from petitioner's gross income as either scholarships or fellowship grants.
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Petitioner was an employee of the Jackson County Public Welfare Commission of the State of Oregon. The petitioner was granted educational leave in 1964 and 1965 in order to attend the University of Washington, School of Social Work. Held, amounts received by the petitioner from the Oregon State Welfare Commission while on educational leave are not excludable from petitioner's gross income as either scholarships or fellowship grants. Sec. 1.117-4(c); Bingler v. Johnson, 394 U.S. 741 (1969).
1Opinion of the Court
OPINION
Section 117(a)2 excludes from gross income any amount received “as a scholarship at an educational institution” or as “a fellowship grant.” The statute does not define the terms “scholarship” and “fellowship grant,” but the regulations provide that amounts representing “compensation for past, present, or future employment services,” and amounts “paid * * * to * * * an individual to enable tiim to pursue studies or research primarily for the benefit of the grantor” are not excludable as scholarships or fellowship grants. Sec. 1.117-4 (c) (1), (2), Income Tax Regs.3 These regulations…
2Cases cited3 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Paul j.ussery and Allean M. Ussery v. United StatesCourt of Appeals for the Fifth Circuit · 1961
- Betty Jane Stewart v. United StatesCourt of Appeals for the Sixth Circuit · 1966
3Cited by25 opinions
- Fisher v. CommissionerUnited States Tax Court · 1971
- Turem v. CommissionerUnited States Tax Court · 1970
- Dietz v. CommissionerUnited States Tax Court · 1974
- Willie v. CommissionerUnited States Tax Court · 1971
- Vaccaro v. CommissionerUnited States Tax Court · 1972
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