Federal Tax Research 10th Edition by Steven Gill, Gerald Whittenburg, Roby Sawyers, Debra Sanders, William Raabe

Exercise 15

State University invites Dr. Byko, a Russian citizen, to become a member of the faculty for a three-year period to work on a large grant the university obtained from the National Aeronautics and Space Administration (NASA). Dr. Byko accepts the invitation and enters the United States on a J-1 visa. His university pay is entirely funded by the NASA grant. Based on the Russian treaty, Dr. Byko thinks his income is exempt because it is from a grant. Determine whether Dr. Byko is correct.