Melissa L. Moloney - Page 7

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          that return, petitioner, inter alia, (1) did not include in gross           
          income petitioner’s LARP award of $4,372 and (2) claimed a                  
          student loan interest deduction of $2,350.                                  
               Respondent issued a notice of deficiency (notice) to peti-             
          tioner for her taxable year 2002.  In that notice, respondent               
          determined to include in gross income petitioner’s LARP award of            
          $4,372.  Respondent also determined in the notice to reduce to              
          $1,622 the amount of the student loan interest deduction that               
          petitioner claimed in petitioner’s 2002 return.                             
                                     Discussion                                       
               The only issue remaining for our consideration is whether              
          petitioner is required to include in gross income for 2002                  
          petitioner’s LARP award of $4,372.3                                         
               In support of her position that she is not required to                 
          include in gross income for 2002 petitioner’s LARP award of                 
          $4,372, petitioner relies on section 108(f).  According to                  
          petitioner,                                                                 
               Looking to both the language of the Internal Revenue                   
               Code Section 108(f) and the award letter for the LARP,                 
               both specify that the person receiving the financial                   
               award must work in a specified employment, in the case                 
               of the LARP, it is full-time employment with the state                 
               or local government or non profit organization.  Look-                 
               ing to the CCH Explanation of Internal Revenue Code                    

               3In the petition and at trial, petitioner made no allega-              
          tions or arguments with respect to respondent’s determination in            
          the notice to reduce the amount of the student loan interest                
          deduction that she claimed in petitioner’s 2002 return.  We                 
          conclude that petitioner does not dispute that determination.               




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