- 5 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011