Betty Jane Stewart v. United States

EDWARDS, Circuit Judge.

Plaintiff-appellant, Betty Jane Stewart, received an educational grant from the Tennessee Department of Public Welfare while an employee of that department to take a year’s work on a Master’s Degree in social work at the University of Tennessee. Her previous salary had been $260 a month. The grant provided her with $175 a month maintenance, plus tuition and travel expense.

Relying upon Section 117 of the Internal Revenue Code of 1954, 1 Miss Stewart asserts that the $175 monthly payments were exempt from income taxes as either a “scholarship” or a “fellowship.”, The…