Thomas J. Rabideau and Sandra M. Rabideau - Page 5

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          of salary.4  In the case of life insurance, the options involve             
          coverage based on different multiples of salary, which range from           
          1 times salary to 4 times salary.                                           
               According to the Met Life manual, if the cost of the                   
          selected benefits is less than the Met Life contribution, then              
          the excess of the Met Life contribution over the cost of the                
          selected benefits is distributed to the employee as cash in his             
          or her wages.  On the other hand, if the cost of the selected               
          benefits is greater than the Met Life contribution, then the                
          excess of the cost of the selected benefits over the amount of              
          the Met Life contribution is deducted from the employee's wages             
          on a pre-tax basis.                                                         
               On November 10, 1988, petitioner completed an enrollment               
          form for participation in Met Life's flexible benefits plan for             
          1989.  On that form, petitioner selected the following "before-             
          tax" benefits:  (1) Medical benefits for himself and his                    
          dependents; (2) dental benefits for himself and his dependents;             
          (3) long-term disability benefits at 60 percent of salary; and              
          (4) life insurance benefits at 4 times salary.  The cost for each           
          of these benefits was $4,448, $495, $502, and $288, respectively,           
          for a total cost of $5,733.  The applicable Met Life contribution           
          applied against the total cost was $4,811.  The difference                  


               4  The amount of disability benefits is also related to the            
          number of years of service that an employee accrues prior to the            
          date of his or her disability.                                              




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