Legal Opinion

Hawronsky v. Commissioner

United States Tax Court

Decided August 8, 1995No. Docket No. 25597-92Published

P received a tax-exempt scholarship from the Indian Health Services Scholarship Program (IHSSP) to attend medical school. IHSSP required P to sign a National Health Services Corp. (NHSC) scholarship program contract mandated by 42 U.S.C. secs. 241l and 254o (1988). Under the contract, P agreed to serve in the Indian Health Service for 4 years. P did not fulfill his service obligation. Instead, he began the practice of medicine at a private clinic.

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P received a tax-exempt scholarship from the Indian Health Services Scholarship Program (IHSSP) to attend medical school. IHSSP required P to sign a National Health Services Corp. (NHSC) scholarship program contract mandated by 42 U.S.C. secs. 241l and 254o (1988). Under the contract, P agreed to serve in the Indian Health Service for 4 years. P did not fulfill his service obligation. Instead, he began the practice of medicine at a private clinic. As a result, P was required by 42 U.S.C. sec. 254o(b)(1)(A) to pay treble damages to the Department of Health and Human Services (HHS). P deducted…

1Opinion of the Court

JOHN W. AND ELIZABETH HAWRONSKY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hawronsky v. Commissioner

Docket No. 25597-92

United States Tax Court

105 T.C. 94; 1995 U.S. Tax Ct. LEXIS 44; 105 T.C. No. 8;

August 8, 1995, Filed

Decision will be entered under Rule 155.

P received a tax-exempt scholarship from the Indian Health Services Scholarship Program (IHSSP) to attend medical school. IHSSP required P to sign a National Health Services Corp. (NHSC) scholarship program contract mandated by 42 U.S.C. secs. 241l and 254o (1988).

Under the contract, P agreed to serve in the Indian Health…

2Cases cited21 opinions

  1. Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
  2. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  3. Rendleman v. BowenCourt of Appeals for the Ninth Circuit · 1988
  4. United States v. Gary D. HatcherCourt of Appeals for the Ninth Circuit · 1991
  5. United States v. Brett Lawrence Arron, M.D.Court of Appeals for the Fifth Circuit · 1992

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