BAILEY v. COMMISSIONER

Docket No. 643-72.

60 T.C. 447 (1973)

GEORGE L. BAILEY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 18, 1973.


Attorney(s) appearing for the Case

L. Joyce Hampers, for the petitioner.

Willard J. Frank, for the respondent.


SIMPSON, Judge:

The respondent determined a deficiency of $783.85 in the petitioner's Federal income tax for the year 1967. The sole issue for decision is whether a training stipend received by the petitioner is a fellowship grant under section 117(a) of the Internal Revenue Code of 1954.1

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found.

The petitioner, George L. Bailey...

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