would the rent & food costs still be considered room & board by the IRS?
Answer According to IRS Publication 970, room and board would be considered eligible for withdrawal without penalty if the student is attending college at least half-time and subject to the greater of two following restrictions. 1) Not more than the allowance for room and board included in the cost of attendance at the eligible institution would be eligible to be withdrawn without penalty or 2) not more than the actual amount charged if the student lived on campus. For more information, please visit: http://www.irs.gov/publications/p970/ch09.html I trust this helps.