SMITH v. COMMISSIONER

Docket No. 5124-71.

60 T.C. 279 (1973)

MICHAEL A. SMITH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 23, 1973.


Attorney(s) appearing for the Case

Barry G. Crown, for the petitioner.

Gary F. Walker, for the respondent.


OPINION

SCOTT, Judge:

Respondent determined a deficiency in petitioner's income tax for the taxable year 1967 in the amount of $419.

The issue for decision is whether the payments petitioner received from the Oldsmobile Division of General Motors Corp. during his work periods while enrolled as a cooperative student with the General Motors Institute constitute a scholarship excludable from his gross income.

All of the facts have been...

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