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We have carefully considered petitioners' remaining
arguments and find them unavailing.7
In conclusion, because the entire cost of petitioner's
disability benefits was attributable to petitioner's employer,
Met Life, and because such benefits were not computed with
reference to the nature of petitioner's disability, such benefits
must be included in petitioners' gross income pursuant to section
105(a).
To reflect our disposition of the disputed issue, as well as
respondent's concession,
Decision will be entered
for respondent as to the
deficiency in income tax and
for petitioners as to the
accuracy-related penalty.
7 Petitioners rely, in part, on the following statement in
IRS Publication 525 at 9 (Taxable and Nontaxable Income): "If you
pay the entire cost of a health or accident insurance plan, do
not include any amounts you receive for your disability as income
on your tax return." In view of our holding that Met Life paid,
or is deemed to have paid, the cost of petitioner's long-term
disability coverage, the foregoing statement is inapposite. Even
if this were not the case, we note that informal IRS publications
are not authoritative sources of Federal tax law; rather,
applicable statutes, regulations, and judicial decisions
constitute the authoritative sources of law that inform our
decisions. E.g., Zimmerman v. Commissioner, 71 T.C. 367, 371
(1978), affd. without published opinion 614 F.2d 1294 (2d. Cir.
1979); Green v. Commissioner, 59 T.C. 456, 458 (1972).
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