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We agree with respondent’s contention that the payments to
petitioner were received by petitioner in her role as a care
provider to Mr. Baldwin and that she was required to provide
attendant and nursing care in order to receive the payments as
compensation for services rendered to Mr. Baldwin. Although we
are sympathetic with petitioner’s circumstances, we are
constrained by the Michigan statute and pertinent caselaw in
defining petitioner’s income for attendant-care services to her
husband as compensation. The payments are therefore includable
in petitioner’s gross income for the years in issue as
compensation for the attendant and nursing care services she
provided to Mr. Baldwin.
Upon the basis of the record, we therefore hold that the
payments to petitioner from Healthcare are includable in her
gross income for the years in issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011