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HALLETT v. UNITED STATES

Civ. A. No. 84-16-NN.

603 F.Supp. 55 (1984)

Ronald A. HALLETT, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Virginia, Newport News Division.

November 1, 1984.

Attorney(s) appearing for the Case

Robert B. Halkowich, Newport News, Va., for plaintiffs.

John F. Kane, U.S. Atty., Norfolk, Va., Sarah Hunt, Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM

WALTER E. HOFFMAN, Senior District Judge.

This cause was tried upon stipulated facts. The central issue is whether certain payments received by plaintiffs, Doris L. Hallett, Olivia D. Zorumski, Peggy H. Smith, Jane P. Reilly and Deborah G. Tanner1 were a scholarship or fellowship and therefore excludable from gross income under § 117 of the Internal Revenue Code.2

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