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However, Ingram’s records, as well as the records of Jefferson-
Pilot, demonstrate that long-term disability coverage was
provided to Ingram’s employees at no cost to the employees.
Although amounts were withheld from petitioner’s salary for other
benefits under the plan, no amounts were withheld for long-term
disability coverage. Given the passage of time involved, it
would appear that petitioner’s memory on the point simply is not
accurate.
The disability payments were received on account of, and
attributed to, accident or health insurance paid for by Ingram.
Pursuant to section 105(a), those amounts are includable and must
be included in petitioner’s income in the year received, and we
so hold. Respondent’s determinations in this regard are
therefore sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Based on the foregoing and to reflect respondent’s
concessions of the additions to tax,
Decision will be
entered for respondent
with respect to the
deficiencies and for
petitioner with respect
to the additions to tax.
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Last modified: May 25, 2011