- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011