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All Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined a deficiency in petitioners' 1991
Federal income tax in the amount of $999. The sole issue for
decision is whether payments received by petitioner Kirk A.
Crandall in 1991 from the Kodak Welfare Benefit Plan Trust are
includable as gross income on petitioners' 1991 Federal income
tax return.
Some of the facts have been stipulated and are so found.
The stipulated facts and attached exhibits are incorporated by
this reference. Petitioners resided in Datil, New Mexico, when
their petition was filed.
On September 1, 1985, petitioner Kirk A. Crandall (Mr.
Crandall) began employment with the Eastman Kodak Company (Kodak)
as a service representative. Approximately 13 months later Mr.
Crandall became disabled. The last date on which he worked at
Kodak was October 17, 1986. In March 1987, Mr. Crandall filed an
application for benefits under the Kodak Long Term Disability
(LTD) Plan (sometimes hereinafter referred to as "the Plan").
His coverage under the Plan became effective March 31, 1987. A
subsequent, lump sum settlement of a disputed worker's
compensation claim filed by Mr. Crandall did not adversely affect
his eligibility for benefits under the Plan.
During 1991, Mr. Crandall received payments from the Kodak
Welfare Benefit Trust in the amount of $5,491.52. Petitioners
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