- 3 -- 3 - requirement. The board certification process was separate from the hematology training program. On their joint 1993 Federal income tax return, petitioners did not include in income the $14,750 fellowship grant received from NIH. Respondent determined that the grant was includable in income. Discussion Section 61(a) defines gross income to mean all income from whatever source derived. The internal revenue statutes and/or case law, however, have recognized in one form or another an exemption for financial aid to persons pursuing education goals. See Spiegelman v. Commissioner, 102 T.C. 394 (1994). Prior to 1986, the exemption from income of scholarship or fellowship payments focused basically on whether the recipient was required to perform services or to provide a benefit for another in a quid pro quo arrangement. Id. at 399-402. The pre-1986 section 117 was amended by section 123 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, 2112. The 1986 change was designed to shift the focus of the tax exemption to the use of the funds. The legislative history highlights the congressional intent: The committee believes that the exclusion for scholarships should be targeted specifically for the purpose of educational benefits, and should not encompass other items which would otherwise constitute nondeductible personal expenses. [H. Rept. 99-426, at 100 (1985), 1986-3 C.B. (Vol. 2) 1, 100.]Page: Previous 1 2 3 4 5 6 7 8 Next
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