Emory v. Commissioner
United States Tax Court
The petitioner, a psychiatric resident, received stipends from the Terrell State Hospital during the period of his residency. The stipends granted to the petitioner represent compensation for present or future services that were subject to the direction or supervision of the grantor. Held, the stipends are not excludable scholarships or fellowship grants. Sec. 117(a), I.R.C. 1954.
1Opinion of the Court
EMERSON EMORY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Emory v. Commissioner
Docket No. 1330-71.
United States Tax Court
T.C. Memo 1973-55; 1973 Tax Ct. Memo LEXIS 233; 32 T.C.M. (CCH) 245; T.C.M. (RIA) 73055;
March 5, 1973, Filed
The petitioner, a psychiatric resident, received stipends from the Terrell State Hospital during the period of his residency. The stipends granted to the petitioner represent compensation for present or future services that were subject to the direction or supervision of the grantor. Held, the stipends are not excludable scholarships or fellowship…
2Cases cited6 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Proskey v. CommissionerUnited States Tax Court · 1969
- Turem v. CommissionerUnited States Tax Court · 1970
- Haley v. CommissionerUnited States Tax Court · 1970
- Kwass v. United StatesDistrict Court, E.D. Michigan · 1970
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