The Basic Opportunity Grants symbolize one approach to the financing of higher education. In this paper, the formula of the grant is tested against the theory and practice of negative income taxation. A key concept in both Basic Opportunity Grants and in other types of income taxation is that of the family unit whose income must be counted in calculating benefits. This concept is critical to the success or failure of the Basic Opportunity Grant in achieving the aims that have been set for it. The conclusion is that college students cannot be held in dependent status in many cases and that this means that some of the arguments for the Basic Opportunity Grants are questionable. (Author)