Legal Opinion

Proskey v. Commissioner

United States Tax Court

Decided March 6, 1969No. Docket No. 4468-67Published

Petitioner was a resident physician at SLU Hospital from Aug. 1, 1961, to July 31, 1962, and at University (of Michigan) Hospital from Aug. 1, 1962, to June 30, 1967. During these years petitioner performed various duties relating to care and treatment of patients, and the hospitals paid him stipends in amounts geared to the number of years of residency he had completed.

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Petitioner was a resident physician at SLU Hospital from Aug. 1, 1961, to July 31, 1962, and at University (of Michigan) Hospital from Aug. 1, 1962, to June 30, 1967. During these years petitioner performed various duties relating to care and treatment of patients, and the hospitals paid him stipends in amounts geared to the number of years of residency he had completed. Held, the stipend petitioner received from University Hospital in 1965 was not a "fellowship grant" as that term is used in sec. 117(a)(1)(B), I.R.C. 1954. Held, further, even if such stipend were a fellowship grant, the…

1Opinion of the Court

Aloysius J. Proskey, Petitioner v. Commissioner of Internal Revenue, Respondent

Proskey v. Commissioner

Docket No. 4468-67

United States Tax Court

51 T.C. 918; 1969 U.S. Tax Ct. LEXIS 175;

March 6, 1969, Filed

Decision will be entered for the respondent.

Petitioner was a resident physician at SLU Hospital from Aug. 1, 1961, to July 31, 1962, and at University (of Michigan) Hospital from Aug. 1, 1962, to June 30, 1967. During these years petitioner performed various duties relating to care and treatment of patients, and the hospitals paid him stipends in amounts geared to the number of years of…

2Cases cited15 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Reese v. CommissionerUnited States Tax Court · 1966
  3. Proskey v. CommissionerUnited States Tax Court · 1969
  4. Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
  5. Bonn v. CommissionerUnited States Tax Court · 1960

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