Hayes P. Duplantis - Page 4




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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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