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CARROLL v. COMMISSIONER

Docket Nos. 3127-71, 336-72.

60 T.C. 96 (1973)

ROBERT W. CARROLL AND BERENICE A. CARROLL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 23, 1973.

Attorney(s) appearing for the Case

J. Nelson Young, for the petitioners.

Walter T. Thompson, for the respondent.

SIMPSON, Judge:

The respondent determined deficiencies in the petitioners' Federal income taxes of $230.67 for 1965 and $265.85 for 1967. The issue for decision is whether payments received by a principal investigator in connection with research performed by him under a basic research grant by the National Science Foundation are excludable fellowship grants within the meaning of section 117(a) of the Internal Revenue Code of 1954.1

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