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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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