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poverty and to provide work incentives to low-income individuals
and that (2) Congress determined that these objectives would not
be furthered if amounts paid for inmates’ services were included
in the definition of earned income. See H. Rept. 103-826 (Vol.
I) (1994); S. Rept. 103-412 (1994); see Sutherland v.
Commissioner, T.C. Memo. 2001-8. Accordingly, Congress enacted
section 32(c)(2)(B)(iv) to exclude from the definition of earned
income any amount received for services provided by an individual
while the individual is an inmate at a penal institution. See
id.
Reviewed and adopted as the report of the Small Tax Case
Division.
Conclusion
In order to give effect to the foregoing,
An order and order and decision
will be entered (1) denying petitioner's
Motion for Summary Judgment, (2) grant-
ing respondent’s Motion for Summary
Judgment, and (3) entering decision for
respondent.
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Last modified: May 25, 2011