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research associate for 1 year, the academic year 1992-1993,
effective August 16, 1992. Petitioner argues that his
appointments as a research assistant or as a research associate
were renewed automatically. If such were the case, it was
incumbent upon petitioner to establish that fact, other than by
his own self-serving testimony. Tokarski v. Commissioner, 87
T.C. 74, 77 (1986); see Wichita Terminal Elevator Co. v.
Commissioner, 6 T.C. 1158 (1946), affd. 162 F.2d 513 (10th Cir.
1947). We would also note that, although petitioner refers to
the total payments in issue as a "stipend", the University refers
to the payments as "salary" or "supplemental compensation". In
no instance in the record does the University refer to the
payments in issue as a "scholarship" or a "fellowship".
The words "scholarship" and "fellowship" are not defined in
the Code. However, the regulations define a scholarship as "an
amount paid or allowed to, or for the benefit of, a student,
whether an undergraduate or a graduate, to aid such individual in
pursuing his studies." Sec. 1.117-3(a), Income Tax Regs.
Similarly, a fellowship is defined as "an amount paid or allowed
to, or for the benefit of, an individual to aid him in the
pursuit of study or research." Sec. 1.117-3(c), Income Tax Regs.
The regulations also provide that scholarship and fellowship
grants do not include "any amount * * * if such amount represents
either compensation for past, present, or future employment
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