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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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