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BINGLER v. JOHNSON

No. 473.

394 U.S. 741 (1969)

89 S.Ct. 1439

22 L.Ed.2d 695

BINGLER, DISTRICT DIRECTOR OF INTERNAL REVENUE v. JOHNSON ET AL.

Supreme Court of United States.

Decided April 23, 1969.

Attorney(s) appearing for the Case

Harris Weinstein argued the cause for petitioner. With him on the briefs were Solicitor General Griswold, Assistant Attorney General Walters, former Assistant Attorney General Rogovin, Jonathan S. Cohen, and Michael B. Arkin.

James C. Larrimer argued the cause and filed a brief for respondents.

MR. JUSTICE STEWART delivered the opinion of the Court.

We are called upon in this case to examine for the first time § 117 of the Internal Revenue Code of 1954, which excludes from a taxpayer's gross income amounts received as "scholarships" and "fellowships." The question before us concerns the tax treatment of payments received by the respondents1 from their employer, the Westinghouse Electric Corporation, while they were on "educational...

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