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SWART v. COMMISSIONER

Docket No. 2580-74.

37 T.C.M. 205 (1978)

T.C. Memo. 1978-38

William M. Swart v. Commissioner.

United States Tax Court.

Filed January 30, 1978.

Attorney(s) appearing for the Case

Scott R. Santerre, for the petitioner. Harry Beckhoff, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioner's income tax for the calendar year 1971 in the amount of $114.70.

The only issue for decision is whether the amount paid by the Rocky Mountain Osteopathic Hospital, Denver, Colorado, to petitioner as a resident in pathology was a fellowship grant under the provisions of section 117, Internal Revenue Code...

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