(plaintiff was medical student that had contractual agreement with University that University would pay plaintiff's tuition, fees and reasonable expenses associated with attendance; upon graduation and completion or residency, plaintiff required to repay amounts by either working in medically underserved community or by paying back twice the amount of all payments received; University paid plaintiff $73,000 and plaintiff did not work in underserved community but paid back $121,440.22 which was twice the principal plaintiff received plus interest; on amended return, plaintiff claimed full amount paid as Schedule C deduction and IRS disallowed amount; trial court judge upheld IRS on basis that amounts for personal expenses and were not deductible under I.R.C. Sec. 265(a)(1) because amounts related to tax-free income; appellate court upheld trial court determination on basis that origin and character of amounts received were personal in nature).