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Neither the Janet L. Hoffman Loan Assistance Repayment Program
nor the Maryland Higher Education Commission refinanced or agreed
to assume all or part of petitioner’s law school loan in connec-
tion with the grant to petitioner of petitioner’s LARP award of
$4,372.
At the time in 2002 petitioner was offered petitioner’s LARP
award, the lender of petitioner’s law school loan was Sun Tech.,
Inc. Thereafter, AFSA became the owner of petitioner’s law
school loan. Neither the original lender of petitioner’s law
school loan nor any subsequent owner of that loan agreed that
petitioner’s law school loan would be forgiven if petitioner were
to work for the State’s Attorney’s Office.
Petitioner’s LARP award of $4,372 was made by means of a
dual-payee check ($4,372 dual-payee check) made out to both
petitioner and AFSA. Petitioner used that check to make a
payment on petitioner’s law school loan. Thereafter, the owner
of that loan issued a statement to petitioner indicating that it
had credited $4,372 against the principal of petitioner’s law
school loan. At no time after petitioner used the $4,372 dual-
payee check to make a payment on petitioner’s law school loan did
the owner of that loan indicate to petitioner that it was forgiv-
ing all or part of that loan.
Petitioner filed Form 1040A, U.S. Individual Income Tax
Return, for her taxable year 2002 (petitioner’s 2002 return). In
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Last modified: May 25, 2011