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Pursuant to the plan, petitioner contributed towards the
cost of life insurance for himself, accidental death and
dismemberment insurance for himself and his wife, medical
insurance for his dependents, and for benefits described as
“daily income while hospitalized”. Petitioner’s contributions
for the above employee benefits were withheld from his salary.
The cost of the long-term disability coverage provided to
petitioner and other employees of Ingram covered under the plan
was paid entirely by Ingram.
During 1982, while descending an interior stairway from the
towboat’s pilothouse, petitioner fell and severely injured his
back. As a result of the injuries sustained in the fall,
petitioner was rendered totally and permanently disabled. At
some point after the fall, he qualified for and began to receive
long-term disability payments under the plan (the disability
payments). The disability payments were calculated based upon
petitioner’s salary, not on the nature of his injury.
Pursuant to his coverage under the plan, petitioner received
disability payments of $13,378 in 1992, and $13,268 in each of
the years 1993, 1994, 1995, and 1996. He did not file a Federal
income tax return for any of those years.
Respondent determined that the disability payments are
includable in petitioner’s income in the year received. Other
adjustments made in the notices of deficiency are not in dispute.
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Last modified: May 25, 2011