- 2 - Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1992, as well as an accuracy- related penalty for negligence under section 6662(a), in the amounts of $6,176 and $1,235, respectively. Respondent subsequently conceded that petitioners are not liable for the accuracy-related penalty. Accordingly, the sole issue for decision is whether petitioners may exclude from gross income the disability benefits that petitioner Thomas J. Rabideau received from his former employer.2 FINDINGS OF FACT Some of the facts have been stipulated, and they are so found. Petitioners resided in Pardeeville, Wisconsin, at the time that their petition was filed with the Court. Petitioner Thomas J. Rabideau (petitioner) was employed by Metropolitan Life Insurance Co. (Met Life) from no later than 1981 through 1989. During 1989, Met Life maintained a "flexible benefits plan", or "cafeteria plan", that allowed eligible employees to select between different types of benefits and cash. Specifically, the flexible benefits plan offered medical, dental, long-term disability, and life insurance benefits to eligible employees of Met Life. 2 An adjustment to petitioners' earned income credit is a mechanical matter, the resolution of which depends on our disposition of the issue for decision.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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