William K. Rundell, Jr., and Shirley A. Rundell v. Commissioner of Internal Revenue

Fifth Circuit

William K. Rundell, Jr., and Shirley A. Rundell v. Commissioner of Internal Revenue

455 F.2d 639, 29 A.F.T.R.2d (RIA) 624, 1972 U.S. App. LEXIS 11151

CourtCourt of Appeals for the Fifth Circuit

DecidedFebruary 23, 1972

Docket71-2858

StatusPublished

Cited by15 cases

This text of 455 F.2d 639 (William K. Rundell, Jr., and Shirley A. Rundell v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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William K. Rundell, Jr., and Shirley A. Rundell v. Commissioner of Internal Revenue, 455 F.2d 639, 29 A.F.T.R.2d (RIA) 624, 1972 U.S. App. LEXIS 11151 (5th Cir. 1972).

Pincite

Opinion

PER CURIAM:

The issue in this case is whether amounts paid the taxpayer by a hospital while he was a resident were excludable from income as a fellowship grant under § 117 of the Internal Revenue Code of 1954. The Tax Court held that the payments were not excludable, P-H Memo T.C., par. 71,040 (1971), and we affirm upon the findings and opinion of the Tax Court.

We see no substantial basis for disturbing the finding that the payments to the resident were compensation for services rendered rather than an educational grant, Bingler v. Johnson, 1969, 394 U.S. '¡41, 89 S.Ct. 1439, 22 L.Ed.2d 695; Reese v. Commissioner of Internal Revenue, 4 Cir., 1967, 373 F.2d 742.

Affirmed.

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PER CURIAM:

The issue in this case is whether amounts paid the taxpayer by a hospital while he was a resident were excludable from income as a fellowship grant under § 117 of the Internal Revenue Code of 1954. The Tax Court held that the payments were not excludable, P-H Memo T.C., par. 71,040 (1971), and we affirm upon the findings and opinion of the Tax Court.

We see no substantial basis for disturbing the finding that the payments to the resident were compensation for services rendered rather than an educational grant, Bingler v. Johnson, 1969, 394 U.S. '¡41, 89 S.Ct. 1439, 22 L.Ed.2d 695; Reese v. Commissioner of Internal Revenue, 4 Cir., 1967, 373 F.2d 742.

Affirmed.

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455 F.2d 639, 29 A.F.T.R.2d (RIA) 624, 1972 U.S. App. LEXIS 11151, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-k-rundell-jr-and-shirley-a-rundell-v-commissioner-of-internal-ca5-1972.

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