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student loans) for a particular degree as a condition to receiving the degree.

The bill provides that amounts otherwise qualifying for exclusion from gross income as a scholarship or fellowship grant under new Code section 117A would not be includible in gross income merely because of a requirement for performance of teaching services, after completion of the postgraduate course of study, for any of a broad class of qualified educational organizations. For this rule to apply, the recipient also must establish that the amount of the award or grant was used for qualified tuition and related expenses, which would be defined as tuition and fees required for enrollment or attendance, and fees, books, supplies, and equipment required for courses at the educational institution.

Effective date

Section 203 of the bill would apply to taxable years beginning after December 31, 1983.

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