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exemption as a qualified scholarship under section 117.
Petitioners resided in Owings Mills, Maryland, when the petition
was filed.
The facts may be summarized as follows. Michael B. Streiff
(petitioner) is a medical doctor. During 1993, petitioner was
engaged in a program at Johns Hopkins University School of
Medicine (Johns Hopkins) "to train biomedical
scientist/postdoctoral fellows in hematology research." During
1993, petitioner received a stipend in the amount of $14,750 as a
fellowship grant from the National Institutes of Health (NIH).
The purpose of the grant was to provide financial support for
postdoctoral fellows interested in pursuing academic experimental
hematology. The grant was not contingent upon any services for
or obligations to NIH or Johns Hopkins. Petitioner spent
approximately 50 hours a week in the laboratory at Johns Hopkins
working on research. Petitioner was not a candidate for a degree
at Johns Hopkins.
During 1993, petitioner was also fulfilling the requirements
to become board certified in hematology and medical oncology.
To qualify for the board exams, petitioner was required to
complete 18 months of experience with inpatient treatment in
hematology and oncology and 24 months of experience with
outpatient treatment. During 1993, petitioner spent 2-1/2 days
per week in a clinic as part of his outpatient experience
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