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She will either have income or be considered a full-time student with the postdoc, won't she ?

You would think, and yet we can't document enrollment, for instance, and she's not working at an acredited institution of higher ed (she's at the NIH mothership).

I suspect you get the credit one way or another.

I would hope so but I would like to find some solid documentation on her status. Basically we could take the credit but can't really document why in case the IRS asks what we were thinking.
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