ENGEL, Circuit Judge.
Dr. Michael Cooney appeals from a judgment of the district court denying him relief in his suit for a refund of 1971 personal income taxes in the amount of $754.36.
The sole issue in this appeal is whether certain payments received by Dr. Cooney during his resident internship at the Mt. Carmel Hospital in Columbus, Ohio, were excludable from gross income as a fellowship grant or scholarship within the meaning of section 117 of the Internal...
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