- 5 -- 5 - agency. B is a candidate for a degree for purposes of this section. Thus, B may exclude from gross income any amount received as a qualified scholarship, subject to the rules set forth in paragraph (d) of this section. [Sec. 1.117- 6(c)(6), Proposed Income Tax Regs., 53 Fed. Reg. 21692 (June 9, 1988).] Petitioner contends that his situation is analogous to the example provided by the regulations. Petitioner argues that, while he was not receiving a degree, he was receiving training that would qualify him for board certification, the equivalent of meeting vocational training requirements. Initially we note that these are proposed regulations and are essentially without precedential value. See Laglia v. Commissioner, 88 T.C. 894, 897 (1987), and cases cited therein. But, even if we were to accept the validity of the position espoused in the proposed regulations, petitioner does not meet the requirements. The grant was for financial support while petitioner was engaged in hematology research, not for the board certification process. As stipulated by the parties, petitioner's board certification process was separate from the grant. The grant neither requires nor contemplates that petitioner will be involved in the process of achieving board certification or any other type of training program. In addition, even if we were to accept petitioner's argument that the grant is somehow linked to the board certification process, the board would have to meet the definitional requirements of an "educational organization" as provided byPage: Previous 1 2 3 4 5 6 7 8 Next
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