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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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