Lawrence A. Ehrhart v. Commissioner of Internal Revenue, Thomas P. Tierney v. Commissioner of Internal Revenue

CAMPBELL, Circuit Judge.

Lawrence A. and Melanie D. Ehr-hart, and Thomas P. and Joann M. Tier-ney appeal from the Tax Court’s decision, 57 T.C. 872, upholding the Commissioner’s determination of deficiencies for the years 1966, 1967 and 1968. 1 The Tax Court decided that “living allowances” paid by insurance companies to their actuarial employees attending Northeastern University Graduate School of Actuarial Science were paid primarily for the benefit of the insurance companies and do not constitute scholarships or fellowships excludable from the gross income of recipients under Section…