Featherston, Judge: Bespondent determined a deficiency in petitioner’s income tax for 1965 in the amount of $748.43. The issues presented for decision are: (1) Whether a stipend in the amount of $5,170.02, received by petitioner during 1965 while a resident physician at University Hospital, University of Michigan, constitutes a fellowship grant, $3,600 of which is excludable under section 117(a) (1) (B) ,…
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