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BILLINGHAM v. COMMISSIONER

Docket No. 550-79.

40 T.C.M. 1075 (1980)

T.C. Memo. 1980-343

Richard P. Billingham and Linda B. Billingham v. Commissioner.

United States Tax Court.

Filed August 27, 1980.

Attorney(s) appearing for the Case

Peter S. Lewicki, 909 Seattle Tower Bldg., Seattle, Wash. 98101, for the petitioners. James A. Nelson, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined deficiencies of $569 and $647 in petitioners' Federal income taxes for 1975 and 1976, respectively. The sole issue for decision is whether certain amounts received by petitioner Richard P. Billingham while a resident at Virginia Mason Hospital qualified as scholarship or fellowship grants excludable from gross income under section 117.1

Findings...

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