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the time he filed his petition, petitioner resided in Aurora,
Colorado.
The sole issue is whether petitioner is required to include
in his gross income an amount paid by the U.S. Army (Army) in
satisfaction of a portion of his existing student loan balance.
The facts may be summarized as follows. Prior to enlisting
in the Army, petitioner incurred student loans to finance his
undergraduate degree. Petitioner enlisted in the Army on June
20, 1989. An enactment known as the Department of Defense
Educational Loan Repayment Programs, 10 U.S.C. sec. 2171 (1988),
authorizes the Secretary of Defense to repay certain student
loans in exchange for service performed on active duty as an
enlisted member in a military specialty specified by the
Secretary. During 1991, petitioner completed a year of service
on active duty in the Army. In 1992, as a result of the prior
year's service, the Army paid $2,985.86 toward petitioner's
outstanding student loan balance (the Army loan repayment).
On a 1992 Federal income tax return, petitioner did not
report any income as a result of the Army loan repayment. In the
notice of deficiency, respondent determined that petitioner
failed to include the Army loan repayment in his 1992 gross
income.
Section 61(a) defines gross income broadly as "all income
from whatever source derived". The Supreme Court "has given a
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