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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 by
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