- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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