- 9 - the additional time to complete his dissertation research and the requirements for the Ph.D. degree. The extension request was granted by NIGMS in June 1990. Petitioner received a stipend of $25,000 and an institutional allowance of $3,000 for the period June 20, 1990, to June 19, 1991. Petitioner remained at CUNY for the extended period of his MARC fellowship; however, he did not complete his Ph.D. degree. OPINION Section 117(a) excludes from gross income any amount received as a scholarship or fellowship grant. Generally, a "scholarship" or "fellowship grant" includes an amount paid to or for the benefit of an individual to aid him or her in the pursuit of study or research. Sec. 1.117-3, Income Tax Regs. The fact that the recipient is required to furnish reports of his or her progress to the grantor does not destroy the essential character of such an amount as a scholarship or fellowship grant. Sec. 1.117-4(c)(2), Income Tax Regs. In Bingler v. Johnson, 394 U.S. 741, 751 (1969), the Supreme Court sustained the validity of these regulations as comporting with the ordinary understanding of scholarships and fellowships as "relatively disinterested, 'no strings' educational grants, with no requirement of any substantial quid pro quo from the recipients." Prior to amendment by the Tax Reform Act of 1986 (TRA 1986), Pub. L. 99-514, sec. 123, 100 Stat. 2085, 2112, section 117 permitted the entire amount of a fellowship grant to be excludedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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