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BROEDEL v. COMMISSIONER

Docket No. 2405-98.

81 T.C.M. 1732 (2001)

T.C. Memo. 2001-135

William J. Broedel and Joan C. Broedel v. Commissioner.

United States Tax Court.

Filed June 8, 2001.

Attorney(s) appearing for the Case

William J. Broedel and Joan C. Broedel, pro sese.

Anne D. Melzer, Edward D. Fickess, and John D. Steele, Jr., for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency of $18,161 in petitioners' joint 1994 Federal income tax. The issues for decision are: (1) Whether $58,372.50 received from the State University of New York Institute of Technology in 1994 is excludable from petitioners' gross income under section 104(a)(2);1 and (2) whether petitioners realized $13,393.54 in income in 1994 from the New York...

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