Proskey v. Commissioner
United States Tax Court
Petitioner was a resident physician at SLU Hospital from Aug. 1, 1961, to July 31, 1962, and at University (of Michigan) Hospital from Aug. 1, 1962, to June 30, 1967. During these years petitioner performed various duties relating to care and treatment of patients, and the hospitals paid him stipends in amounts geared to the number of years of residency he had completed.
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Petitioner was a resident physician at SLU Hospital from Aug. 1, 1961, to July 31, 1962, and at University (of Michigan) Hospital from Aug. 1, 1962, to June 30, 1967. During these years petitioner performed various duties relating to care and treatment of patients, and the hospitals paid him stipends in amounts geared to the number of years of residency he had completed. Held, the stipend petitioner received from University Hospital in 1965 was not a "fellowship grant" as that term is used in sec. 117(a)(1)(B), I.R.C. 1954. Held, further, even if such stipend were a fellowship grant, the…
1Opinion of the Court
Featherston, Judge:
Bespondent determined a deficiency in petitioner’s income tax for 1965 in the amount of $748.43. The issues presented for decision are: (1) Whether a stipend in the amount of $5,170.02, received by petitioner during 1965 while a resident physician at University Hospital, University of Michigan, constitutes a fellowship grant, $3,600 of which is excludable under section 117(a) (1) (B) ,1 or compensation for services rendered to the hospital, taxable under section 61; and (2) if the stipend is a fellowship grant, whether an exclusion is disallowed by section 117 (b) (2) (B).
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2Cases cited13 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Reese v. CommissionerUnited States Tax Court · 1966
- Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
- Bonn v. CommissionerUnited States Tax Court · 1960
- Bhalla v. CommissionerUnited States Tax Court · 1960
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3Cited by133 opinions
- Anderson v. CommissionerUnited States Tax Court · 1970
- Weinberg v. CommissionerUnited States Tax Court · 1975
- Dr. Hollis K. (Iii) and Patricia D. Leathers v. United States of America Dr. William F. And June B. Blankenship v. United StatesCourt of Appeals for the Eighth Circuit · 1972
- Bailey v. CommissionerUnited States Tax Court · 1973
- Fisher v. CommissionerUnited States Tax Court · 1971
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