WILLIAM K. RUNDELL, JR., AND SHIRLEY A. RUNDELL, PETITIONERS-APPELLANTS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE
WILLIAM K. RUNDELL, JR., AND SHIRLEY A. RUNDELL, PETITIONERS-APPELLANTS,
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE
455 F.2d 639
Court of Appeals for the Fifth Circuit (1972)
Positive Treatment
Cited by 6 cases
Opinion of the Court
PER CURIAM:
The issue in this case is whether amounts paid the taxpayer by a hospital while he was a resident were excludable from income as a fellowship grant under § 117 of the Internal Revenue Code of 1954. The Tax Court held that the payments were not excludable, P-H Memo T.C., par. 71,040 (1971), and we affirm upon the findings and opinion of the Tax Court.
We see no substantial basis for disturbing the finding that the payments to the resident were compensation for services rendered rather than an educational grant, Bingler v. Johnson, 1969, 394 U.S. '¡41, 89 S.Ct. 1439, 22 L.Ed.2d 695; Reese v. Commissioner of Internal Revenue, 4 Cir., 1967, 373 F. 2d 742.
Affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Dr. Hollis K. (III) and Patricia D. Leathers v. United States, 471 F.2d 856 (8th Cir. 1972)
-
Parr v. United States, 469 F.2d 1156 (5th Cir. 1972)
-
Palmer F. Meek and Martha A. Meek v. United States, 608 F.2d 368 (9th Cir. 1979)
Authorities Cited
- Isbell Enters., Inc. v. Citizens Cas. Co. OF NEW York, 431 F.2d 409 (5th Cir. 1970)
- Bingler v. Johnson, 394 U.S. 741 (U.S. 1969)
- Reese v. Commissioner OF Internal Revenue, 373 F.2d 742 (4th Cir. 1967)