Robert N. Worthington and Svaja v. Worthington v. Commissioner of Internal Revenue

Appellants 1 appeal from an adverse decision of the Tax Court sustaining the Commissioner of Internal Revenue’s assessment of a tax deficiency for the year 1968 in the amount of $552.38. The issue before the Tax Court was whether $2,700.00 received by appellant during the taxable year 1968 as a teaching assistant in the English Department of the University of New Mexico was excludable from gross income for that year under the provisions of Section 117 of the Int.Rev.Code of 1954. 2 The Tax Court found that it was not. We agree.

The facts are not in dispute. In the fall of 1967, appellant was…