Kirk A. and Ida R. Crandall - Page 4

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          contributions by the employer that were not includable in the               
          gross income of the employee, or (2) are paid by the employer.              
          Sec. 105(a), (e).                                                           
               Documents stipulated by the parties in this case establish             
          that the payments received by Mr. Crandall from the Kodak Welfare           
          Benefit Trust were made under the Kodak Long Term Disability                
          (LTD) Plan, and that Kodak funded the Kodak Welfare Benefit Trust           
          without any contributions from employees.                                   
               The parties stipulated into the record a copy of select                
          portions of an undated employee handbook (hereinafter "the                  
          employee handbook"), in addition to a copy of applicable portions           
          of an undated booklet issued by Kodak that explained the Kodak              
          LTD Plan (sometimes hereinafter referred to as "Kodak's Long Term           
          Disability booklet" or "the booklet").  The copied material had             
          been provided to respondent in 1995 by Nick Laino, a manager in             
          the Disability Management Services unit of the Metropolitan Life            
          Insurance Company (MetLife).  At the time, MetLife was                      
          responsible for reviewing claims under the Plan and assisting               
          Kodak in general planning.                                                  
               The employee handbook states:  "The plan is known as the               
          Kodak Long Term Disability (LTD) Plan and is sponsored and                  
          maintained on an uninsured basis by Eastman Kodak Company".  It             
          states further:                                                             
               The Kodak Welfare Benefit Plan Trust with Citibank,                    
               N.A., as trustee, has been established to accumulate                   
               assets of the plan and to provide funds for benefit                    




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