Weiner v. Commissioner
United States Tax Court
P was awarded a postdoctoral fellowship grant to perform research. At the same time, P registered for courses in a graduate medical program which would have led to granting of a degree. There were no requirements under the fellowship that P take courses or become a candidate for a degree. Held, the exclusion of the fellowship is limited to $ 300 per month. Sec. 117, I.R.C. 1954.
1Opinion of the Court
Wiles, Judge:
Respondent determined a deficiency in petitioner’s income tax for the year 1970 in the amount of $2,295.52. The issue is whether petitioner is entitled to exclude the entire amount of a fellowship grant received by him during the year 1970.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Melvin H. Weiner (hereinafter referred to as petitioner) was a legal resident of the State of Colorado at the time the petition was filed. Petitioner filed his income tax return for 1970 with the District Director of Internal Revenue in Denver, Colo.
Petitioner…
2Cases cited7 opinions
- Reese v. CommissionerUnited States Tax Court · 1966
- Bhalla v. CommissionerUnited States Tax Court · 1960
- Steiman v. CommissionerUnited States Tax Court · 1971
- Rosenthal v. CommissionerUnited States Tax Court · 1975
- Jamieson v. CommissionerUnited States Tax Court · 1969
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Johnson v. CommissionerUnited States Tax Court · 1978
- Weiner v. CommissionerUnited States Tax Court · 1975