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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 the
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