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WOLPAW v. C. I. R.

No. 93-2175.

47 F.3d 787 (1995)

Daniel R. WOLPAW; Theresa M. Wolpaw, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided February 17, 1995.

Attorney(s) appearing for the Case

Frederick N. Widen (argued and briefed), Kahn, Kleinman, Yanowitz & Arnson, Cleveland, OH, for petitioners-appellants.

Teresa McLaughlin, Marion E.M. Erickson (argued and briefed), Gary R. Allen, Acting Chief (briefed), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, DC, for respondent-appellee.

Before: MARTIN, KRUPANSKY and BOGGS, Circuit Judges.

BOYCE F. MARTIN, Jr., Circuit Judge.

Daniel and Theresa Wolpaw appeal a Tax Court decision requiring them to include in gross income the value of tuition waivers for Theresa Wolpaw's medical school education at Case Western Reserve University. 66 T.C.M. (CCH) ¶ 49,164(M) (No.1993-322). The Tax Court reached its decision by interpreting Section 1853(f)(3)(A) of the Tax Reform Act of 1986, Pub.L. No. 99-514, 100 Stat. 2085, 2872 (Oct. 22, 1986) (codified at 26...

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