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RUNDELL v. COMMISSIONER

Docket No. 2567-70-SC.

30 T.C.M. 177 (1971)

T.C. Memo. 1971-40

William K. Rundell, Jr. and Shirley A. Rundell v. Commissioner.

United States Tax Court.

Filed March 3, 1971.

Attorney(s) appearing for the Case

G. Lynn Smith, 524 Southland Center, Dallas, Tex., for the petitioners. John W. Dierker, for the respondent.

Memorandum Findings of Fact and Opinion

GUSSIS, Commissioner:

Respondent determined a deficiency in the petitioners' Federal income tax for the year 1968 in the amount of $836.87. The issue is whether a portion of the amounts received by petitioner William K. Rundell, Jr. in 1968 while a resident at St. Paul Hospital was excludable from income as a fellowship grant within the meaning of section 117 of the Internal Revenue Code of 1954.1...

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