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guage of the Internal Revenue Code Section 108(f) is
general to provide a template from which to make deci-
sions thus allowing for programs, such as the Janet L.
Hoffman LARP to be governed by it. Both the letter of
the law and the spirit of the law is served by making
the award money received non taxable, thus allowing
professionals to serve the public and still be able to
pay their debt. [Reproduced literally.]
Respondent counters petitioner’s argument under section
108(f) as follows:
Her [petitioner’s] argument glosses over the fact that
the award is not a discharge of indebtedness. Even if
the award were considered to be a discharge of indebt-
edness, it would not be excludible from income under
I.R.C. � 108(f) under the plain language of the stat-
ute. Petitioner attempts to avoid the language of the
statute by arguing that the intent of the award falls
within the intent behind the law. * * * She fails to
recognize that this reading of I.R.C. � 108(f) is
without foundation.
We turn first to section 108(f) on which petitioner relies.
That section provides:
SEC. 108. INCOME FROM DISCHARGE OF INDEBTEDNESS.
* * * * * * *
(f) Student Loans.--
(1) In General.-–In the case of an individual,
gross income does not include any amount which (but for
this subsection) would be includible in gross income by
reason of the discharge (in whole or in part) of any
student loan if such discharge was pursuant to a provi-
sion of such loan under which all or part of the in-
debtedness of the individual would be discharged if the
individual worked for a certain period of time in
certain professions for any of a broad class of employ-
ers.
(2) Student Loan.-–For purposes of this subsec-
tion, the term “student loan” means any loan to an
individual to assist the individual in attending an
educational organization described in section
170(b)(1)(A)(ii) made by–-
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