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TATE v. COMMISSIONER

Docket No. 12045-81.

47 T.C.M. 1611 (1984)

T.C. Memo. 1984-206

Douglas Y. Tate and Corinne J. Tate v. Commissioner.

United States Tax Court.

Filed April 24, 1984.

Attorney(s) appearing for the Case

Christine R. Mayer, 420 Delaware St. S.E., Minneapolis, Minn., for the petitioners. Dale L. Newland, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined a deficiency in petitioners' Federal income taxes for tax year ended December 31, 1977, in the amount of $2,015.

After concessions, the sole issue for decision is whether petitioners may exclude from their gross income, pursuant to section 117,1 certain payments received by petitioner while he was a candidate for a doctoral degree, and serving...

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