- 18 - degree given by a college or university. We note that petitioner's goal in obtaining a MARC faculty fellowship was to continue his Ph.D. thesis research and ultimately receive the research doctorate. Based on the record in this case, we are satisfied that petitioner was required to enroll in the master's program at CUNY as a stepping stone toward reaching his ultimate goal, the Ph.D. degree. Thus, we find that petitioner took courses in the master's program at CUNY designed to meet the requirements for receiving a degree from that institution, and that petitioner was a candidate for a degree during the years in issue within the meaning of section 117. As we have concluded above, section 117 prior to amendment by TRA 1986 applies to the fellowship payments petitioner received in 1989 and during approximately the first half of 1990; section 117 as amended applies to the fellowship payments received thereafter (i.e., pursuant to petitioner's request for a 1-year extension of his MARC fellowship commencing on June 20, 1990). Since petitioner was a candidate for a degree during the years in issue, he is entitled to exclude all fellowship amounts received under the earlier version of section 117, and only those fellowship amounts used for "qualified tuition and related expenses" under amended section 117. Petitioner, however, failed to provide any evidence of the amount he spent on tuition, books, fees, and other related expenses while at CUNY, nor did he provide a copy of his transcript or other notification from thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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