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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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Last modified: May 25, 2011