IRA Early Withdrawal Qualified Education Expenses Room and Board

Hi,

I am a full-time graduate student and am planning on taking an early withdrawal from a traditional IRA to help pay bills.  In IRS publication 970 (Ch 9) there are qualified education expenses that the withdrawal can be used for to avoid the 10% early withdrawal penalty.  One such item is room and board, however, I do not live on campus or in a university affiliated complex, I just rent an apartment off-campus.  Can I count my rent as room and board?  I have not been able to find tax documentation outlining this and the people on the IRS helpline could not give me a definitive answer.  Thanks!