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made by Met Life that were not includable in petitioners' gross
income.
We begin by addressing petitioners' primary contention that
the contributions for petitioner's disability benefits were paid
with funds that petitioner could have received if he had elected
to receive cash in lieu of benefits.
Petitioners' contention is not supported by the record.
Here we recall that Met Life employees were required to select
long-term disability coverage (as well as life insurance
coverage). Petitioner did not have the option, therefore, of
forgoing long-term disability coverage and receiving instead cash
in an amount equivalent to the cost of such coverage. In other
words, petitioner could not have increased his take home pay by
forgoing long-term disability coverage (or by forgoing life
insurance coverage).
We further recall that the cost of the coverage for long-
term disability and life insurance, which coverage petitioner was
required to select, was less than the Met Life contribution of
$881 that was allocable to petitioner if he did not select any
medical and dental coverage. In other words, the cost of the
required coverage, given the options as selected by petitioner,
was $790 (i.e., $502 for long-term disability and $288 for life
insurance), and this amount was $91 less than the aforementioned
Met Life contribution of $881. Thus, Met Life effectively paid
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