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KADIVAR v. COMMISSIONER

Docket No. 1302-72.

32 T.C.M. 427 (1973)

T.C. Memo. 1973-95

Esfandiar Kadivar v. Commissioner.

United States Tax Court.

Filed April 24, 1973.

Attorney(s) appearing for the Case

Esfandiar Kadivar, pro se, Dixmyth Ave. Apt. 816, Cincinnati, Ohio. Rudolf L. Jansen, for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined deficiencies in the 1970 income tax liability of Esfandiar Kadivar in the amount of $3,137.58. There are 3 issues:

(1) Whether petitioner properly excluded from income $3,600 of the combined payments he received during 1970 from the hospital where he completed a medical internship and from the hospital where he commenced a surgical residency program.

(2)...

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