Irvin Heard, Jr. - Page 2

                                        - 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 Howard             





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