I previously blogged the Tax Court’s summary opinion in Moloney v. Commissioner, T.C. Summ. Op. 2006-53 (4/17/06), which held that a law school graduate working in a public interest job must report income on the receipt of funds to help repay her student loans, as well as commentary on the case by Tax Prof and Associate Dean Ellen Aprill (Loyola-L.A.) and her subsequent letter to the Treasury and IRS about the decision.

Virginia Dean John C. Jeffries, Jr. and Tax Prof (and former Chief of Staff of the Joint Committee on Taxation) George K. Yin have written this five-page letter to the Treasury and IRS requesting clarification of the scope of § 108(f)(1) to law school public interest loan forgiveness programs in light of the Maloney decision.