Thomas J. Rabideau and Sandra M. Rabideau - Page 10

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          in full the cost of petitioner's long-term disability coverage.             
          Pursuant to section 105(a), the long-term disability benefits               
          received by petitioner pursuant to such coverage would therefore            
          be includable in petitioners' gross income.                                 
               Petitioners seek to avoid the foregoing conclusion by                  
          focusing on the fact that petitioner selected benefits for which            
          the total cost ($5,733) exceeded the Met Life contribution                  
          ($4,811).  Because such excess (i.e., $922) was deducted from               
          petitioner's wages, and because such excess exceeded the cost of            
          petitioner's long-term disability coverage, petitioners argue               
          that petitioner's long-term disability benefits should be                   
          excluded from gross income.                                                 
               Petitioners' argument overlooks the fact that the cost of              
          petitioner's benefits exceeded the Met Life contribution only               
          because petitioner selected medical and dental coverage for                 
          himself and his dependents.  In other words, the excess of the              
          total cost of benefits over the Met Life contribution is                    
          allocable to the cost of medical and dental coverage and not to             
          the cost of long-term disability coverage.  Indeed, as previously           
          stated, the combined cost of long-term disability coverage and              
          insurance coverage was $91 less than the Met Life contribution if           
          petitioner had forgone medical and dental coverage.                         
               In summary, after careful consideration, we conclude that              
          the cost of petitioner's long-term disability coverage was                  






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