Robert Charles Fohrmeister - Page 6

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          default.  We, therefore, sustain respondent's determination on              
          this issue.                                                                 
          2.  Form W-2 Income                                                         
               During a portion of 1991, petitioner was employed by                   
          Strahman Valves, Inc. (Strahman).  On his 1991 return, petitioner           
          reported wage income attributable to his employment at Strahman             
          in the amount of $20,694.16.  Respondent determined that                    
          petitioner was liable for unreported wage income in the amount of           
          $23.20.  The parties agree that the amount in question relates to           
          the cost of the portion of employer-provided group term life                
          insurance for coverage in excess of $50,000.                                
               Section 79(a) provides that an employee shall include in his           
          gross income the cost of group term life insurance on his life,             
          provided under a policy carried by his employer, but only to the            
          extent that the cost exceeds the sum of the cost of $50,000 of              
          the insurance plus any amounts paid by the employee toward the              
          purchase of the insurance.  Petitioner does not dispute that the            
          $23.20 represents the cost of employer-provided coverage on his             
          life in excess of the cost of $50,000 in coverage.  Rather,                 
          petitioner argues that because his earned income was less than              
          $50,000 during 1991, the amount in question should not be                   
          taxable.                                                                    
               Petitioner has misinterpreted section 79.  The $50,000                 
          threshold refers to the employee's coverage amount under a group            
          term life insurance policy, not to the employee's earned income.            




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