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WODDAIL v. C. I. R.

No. 7287.

321 F.2d 721 (1963)

Joseph D. WODDAIL and Susan M. Woddail, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Tenth Circuit.

August 13, 1963.

Attorney(s) appearing for the Case

Robert F. Roeser, Atlanta, Ga., for petitioners.

Harold C. Wilkenfeld, Atty., Dept. of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Earl J. Silbert, Attys., Dept. of Justice, were with him on the brief), for respondent.

Before PICKETT, BREITENSTEIN and HILL, Circuit Judges.

HILL, Circuit Judge.

This is a petition to review a decision of the Tax Court of the United States1 which was adverse to the petitioners. The sole question presented is whether any part or all of the amount paid to the taxpayer, Joseph D. Woddail, while he was employed as a full-time physician in the Winter Veterans Administration Hospital, Topeka, Kansas,2 was excludable from gross income as a "fellowship...

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