MacDonald v. Commissioner
United States Tax Court
Held, payments received by T from his employer (IBM) in the full amount of his salary while pursuing studies at a university for a Ph. D. under an employer-sponsored advanced education program were not excludable from gross income as a "scholarship" or "fellowship grant". Sec. 117(a), I.R.C. 1954; secs. 1.117-3(a) and (c), and 1.117-4(c), Income Tax Regs.
1Opinion of the Court
OPINION
Raum, Judge:
At issue is whether petitioner’s full salary of $15,300 paid to him in 1961 by IBM while he was pursuing his studies towards a Ph. D. degree is excludable from his gross income as a “scholarship” or “fellowship grant” under section 117, I.R.C. 1954.1 These terms have been defined and limited in Income Tax Regs, section 1.117-3 and 4,2 which have recently been held valid by the Supreme Court in Bingler v. Johnson, 394 U.S. 741 (1969). And under these regulations amounts representing “compensation for past, present, or future employment services” and amounts paid to an…
2Cases cited5 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
- Paul j.ussery and Allean M. Ussery v. United StatesCourt of Appeals for the Fifth Circuit · 1961
- Farrara v. CommissionerUnited States Tax Court · 1965
- Betty Jane Stewart v. United StatesCourt of Appeals for the Sixth Circuit · 1966
3Cited by32 opinions
- Bailey v. CommissionerUnited States Tax Court · 1973
- Turem v. CommissionerUnited States Tax Court · 1970
- Brubakken v. CommissionerUnited States Tax Court · 1976
- Bieberdorf v. CommissionerUnited States Tax Court · 1973
- Ehrhart v. CommissionerUnited States Tax Court · 1972
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