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an “educational grant”--that should not be includable in his
income.1
The record in this case does not clearly indicate whether
the payment petitioner received was related to the expenses he
incurred in connection with his undergraduate education at
Howard. However, even assuming that the payments were made in
connection therewith, as explained in detail below they would
nonetheless be includable in petitioner’s gross income.
Gross income generally includes all income from whatever
source derived, including “Compensation for services, including
fees, commissions, fringe benefits, and similar items”, unless
excluded by statute. Sec. 61(a)(1). There are several statutory
exclusions which arguably could be applicable to the case at
hand.
First, section 117(a) excludes from gross income “any amount
received as a qualified scholarship by an individual who is a
candidate for a degree” at certain educational institutions. A
“qualified scholarship” does not include any amount received by a
student which represents payment for services required as a
condition for receiving such amount. Sec. 117(c). As is
relevant to the case at hand, the regulations state that the
1At trial, petitioner argued that the amount of the
reimbursement was $7,614. In his petition, petitioner stated
that the amount of the reimbursement was $6,800.
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