- 2 - Additions to Tax Year Deficiency Sec. 6651(a) Sec. 6654 1989 $7,011 $1,711 $463 1990 6,653 1,663 441 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for our consideration are whether amounts received by petitioner qualify as a fellowship grant excludable from income under section 117 and whether petitioner is liable for the additions to tax stated above. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner resided in Palisades Park, New Jersey, at the time the petition was filed in this case. Petitioner attended Southern University in New Orleans, Louisiana, from June 1968 to May 1973, earning a B.S. in physics and a minor in math. From August 1974 to May 1980 petitioner attended Howard University in Washington, D.C., earning a master's degree in physics. After receiving his master's degree, petitioner remained at Howard for an additional 2 years pursuing a Ph.D. degree in physics, but he did not complete the required Ph.D. thesis research during that time. Petitioner left HowardPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011