Melissa L. Moloney - Page 3

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               Respondent determined a deficiency of $1,377 in petitioner’s           
          Federal income tax for her taxable year 2002.                               
               The issue remaining for decision is whether petitioner is              
          required to include in gross income for her taxable year 2002 a             
          $4,372 award that she received in that year.  We hold that she              
               Virtually all of the facts have been stipulated by the                 
          parties and are so found.                                                   
               At the time petitioner filed the petition in this case, she            
          resided in Baltimore, Maryland.                                             
               Throughout the period 1996 through 1999, the Federal                   
          Stafford Loan (Subsidized and Unsubsidized) Program made educa-             
          tional loans totaling approximately $55,000 to petitioner that              
          she used to pay expenses that she incurred in attending law                 
          school (petitioner’s law school loan).  Neither the note nor any            
          other documents relating to that loan provided that petitioner’s            
          law school loan would be forgiven if petitioner were to work                
          after law school for the Baltimore County State’s Attorney’s                
          Office (State’s Attorney’s Office).                                         
               In 2002, the Janet L. Hoffman Loan Assistance Repayment                
          Program (LARP), through the Maryland Higher Education Commission,           
          offered petitioner an award of $4,372 for the 2002-2003 award               
          year (petitioner’s LARP award) that was to be used to repay part            

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