Chander and Ashima K. Kant - Page 10

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            as a condition for receiving payments as an employee from NUS.                            
            Cf. Spiegelman v. Commissioner, 102 T.C. 394, 406 (1994)                                  
            (concluding that recipient of taxable research fellowship was not                         
            liable for self-employment tax).                                                          
                  Therefore, we conclude that the $27,191 received from NUS                           
            was properly reportable as wage income.  Furthermore, as a result                         
            of this conclusion, respondent's claim for an increased                                   
            deficiency (relating to the disallowed child care credit) is                              
            sustained.                                                                                
                  To reflect the foregoing,                                                           
                                                            Decision will be entered                  
                                                      for respondent as to the                        
                                                      deficiency and for petitioners                  
                                                      as to the accuracy-related                      
                                                      penalty.                                        





















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