BRUBAKKEN v. COMMISSIONER

Docket No. 3790-75.

67 T.C. 249 (1976)

DAVID M. BRUBAKKEN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 18, 1976.


Attorney(s) appearing for the Case

Robert D. Heidel and Lorence D. Wheeler, for the petitioner.

Scott R. Cox, for the respondent.


SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioner's Federal income taxes in the amounts of $517 for 1971 and $1,941.68 for 1972. The sole issue for decision is whether payments received by the petitioner, a psychology intern, are excludable from gross income as a scholarship or fellowship grant under section 117(a) of the Internal Revenue Code of 1954.1

FINDINGS OF FACT

Some of the facts...

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