Dietz v. Commissioner
United States Tax Court
Held: Amounts received by the petitioner in a residency program in general psychiatry did not constitute income from a "fellowship grant" within the meaning of sec. 117, I.R.C. 1954, notwithstanding the fact that such programs were funded by the National Institute of Mental Health in order to encourage the pursuit of that specialty.
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Held: Amounts received by the petitioner in a residency program in general psychiatry did not constitute income from a "fellowship grant" within the meaning of sec. 117, I.R.C. 1954, notwithstanding the fact that such programs were funded by the National Institute of Mental Health in order to encourage the pursuit of that specialty. As a condition of the residency, petitioner was required to render services in the field of mental health both to the medical school and to the hospital involved.
1Opinion of the Court
Quealt, Judge:
Respondent determined deficiencies in the Federal .income tax of petitioners for the taxable years 1968 and 1969 in the amounts of $1,926 and $694.46, respectively.
Due to concessions by the parties, the sole question before the Court for decision is whether any of the amounts paid to petitioner Johanna C. Dietz by the University of Texas Southwestern Medical School from the National Institute of Mental Health grants in each of the taxable years 1968 and 1969 for her participation in that school’s •residency program in general psychiatry is excludable from gross income as a…
2Cases cited6 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Reese v. CommissionerUnited States Tax Court · 1966
- Proskey v. CommissionerUnited States Tax Court · 1969
- Bailey v. CommissionerUnited States Tax Court · 1973
- Bieberdorf v. CommissionerUnited States Tax Court · 1973
1 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Weinberg v. CommissionerUnited States Tax Court · 1975
- Rosenthal v. CommissionerUnited States Tax Court · 1975
- Adams v. CommissionerUnited States Tax Court · 1978
- Meehan v. CommissionerUnited States Tax Court · 1976
- Yarlott v. Comm'rUnited States Tax Court · 1982
35 more not listed; retrieve them via the Exa API.