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Taxability Of Scholarships And Fellowships, Myron S. Zwibelman
Taxability Of Scholarships And Fellowships, Myron S. Zwibelman
Missouri Law Review
Since section 117 of the Internal Revenue Code was enacted in part to end the confusion created by the gift-compensation test under the 1939 Code, one might expect the section to resolve the basic definitional issue: which payments qualify as scholarship and fellowships? Yet, nowhere in section 117 or in its legislative history are the terms scholarship and fellowship defined. Either Congress was satisfied that these terms had generally accepted meanings which were not open to question or that there was no simple definition which would resolve the hard cases and that these might better be left to resolution by …