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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
is.
Background
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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