Fordham Seeks Clarity on Tax Treatment of Law School Debt

Since Moloney v. Commissioner, T.C. Summary Opinion 2006- 53, which included a footnote that only medicine, nursing and teaching were "certain professions" eligible for tax-free loan forgiveness under section 108(f), we at Fordham Law School have been concerned about the tax treatment of our law school loan forgiveness program. Given the high cost of law school education and the enormous debt burden of so many of our students, this program is an important tool in enabling and encouraging our graduates to do public interest law. We respectfully request that, based on the legislative history and purpose of the current version of section 108(f), you issue administrative guidance that section 108(f) applies to law school loan forgiveness programs.