Legal Opinion

Ehrhart v. Commissioner

United States Tax Court

Decided March 28, 1972No. Docket Nos. 2597-70, 2911-70, 5788-70Published

Held, "living allowances" paid by insurance companies to their actuarial employees attending the Northeastern University Graduate School of Actuarial Science were paid primarily for the benefit of the insurance companies and do not constitute scholarships or fellowships excludable from gross income of the recipients under sec. 117(a)(1), I.R.C. 1954.

1Opinion of the Court

Lawrence A. and Melanie D. Ehrhart, Petitioners v. Commissioner of Internal Revenue, Respondent; Thomas P. and Joann M. Tierney, Petitioners v. Commissioner of Internal Revenue, Respondent

Ehrhart v. Commissioner

Docket Nos. 2597-70, 2911-70, 5788-70

United States Tax Court

57 T.C. 872; 1972 U.S. Tax Ct. LEXIS 155;

March 28, 1972, Filed

Decisions will be entered for the respondent.

Held, "living allowances" paid by insurance companies to their actuarial employees attending the Northeastern University Graduate School of Actuarial Science were paid primarily for the benefit of the insurance companies…

2Cases cited9 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. Reese v. CommissionerUnited States Tax Court · 1966
  3. Proskey v. CommissionerUnited States Tax Court · 1969
  4. Turem v. CommissionerUnited States Tax Court · 1970
  5. MacDonald v. CommissionerUnited States Tax Court · 1969

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