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Respondent determined deficiencies in and additions to
petitioner’s Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1992 $1,129 $282 $49
1993 1,099 274 46
1994 1,069 267 55
1995 1,046 262 57
1996 1,196 239 64
For each year, the issue for decision is whether long-term
disability payments received by petitioner are includable in
income.
Background
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
Metairie, Louisiana.
Petitioner was employed as a towboat captain by Ingram
Industries, Inc. (Ingram), from 1979 until he was injured in an
accident that occurred in 1982. As an employee of Ingram,
petitioner was eligible for certain employee benefits, including
life insurance, medical care for himself and his family, and
long-term disability benefits. These benefits were made
available to petitioner and other eligible employees of Ingram
through a group insurance plan (the plan) subscribed to by
Ingram underwritten by Jefferson-Pilot Life Insurance Co.
(Jefferson-Pilot).
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Last modified: May 25, 2011