Thomas J. Rabideau and Sandra M. Rabideau - Page 12

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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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