Dowd v. Commissioner

OPINION.

Raum, Judge:

1. Petitioner’s claim to exclusion from gross income rests solely upon section 911(a) (2) of the 1954 Code.1 There is no contention before us that the amounts received by petitioner were excludible under section 117 pertaining to “Scholarships and Fellowship Grants.” See Rev. Rui. 61-65, 1961-1 C.B. 17. The grants to petitioner related to his activities as a lecturer, and he seeks favored tax treatment only under section 911(a) (2) dealing with income earned outside the United States where the taxpayer “during any period of 18 consecutive months is present in a foreign…