Respondent determined a deficiency in petitioners' 1992
Federal income tax in the amount of $3,655.
A concession having been made by petitioners,2 the issues
remaining for decision are: (1) Whether $7,141 of the $15,846
(rounded) received by Dean W. Schulze (petitioner) as a graduate
associate at the University of Arizona (University) is excludable
from gross income; and (2) whether petitioner may deduct $1,016
paid as tuition to the University in 1992.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioners resided in Tucson,
Arizona, on the date the petition was filed in this case.
In the fall of 1985, petitioner enrolled in the graduate
program at the University to obtain a Master of Science in
Physics (Masters Program). On August 11, 1986, while in the
Masters Program, petitioner became a research assistant in the
Physics Department. He testified at trial that his duties as a
research assistant were to engage in original research that would
be suitable for publication in a reference journal, which are the
University's and the Physics Department's requirements for a
Ph.D.
We would note that in 1986 petitioner was not in a doctoral
program; he was not a candidate for a Ph.D. He was in the
2 Petitioners concede that, under their theory of the
case, $8,705 of the $15,846 received by petitioner, Dean W.
Schulze, from the University of Arizona in 1992, is not
excludable from income.
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