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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 excluded
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