- 3 - A. Disability Benefits Petitioner D. Lloyd Thomas (petitioner) was employed by the Texas Department of Criminal Justice as an associate clinical psychologist from August 1994 through February 1999. In or about February 1997, petitioner suffered a herniated disk. Petitioner’s injury was sufficiently severe as to require bed rest and home confinement for a continuous period of time that extended through July 1997. During the first 2 months of his 6-month absence from work, petitioner utilized his accumulated sick leave and annual leave. After exhausting his leave, petitioner began receiving disability benefits. For the period from April 2 through July 30, 1997, petitioner received disability benefits in the amount of $4,964. Petitioner received disability benefits pursuant to a plan of disability insurance that was sponsored by his employer. However, the premiums for such insurance were paid solely by petitioner with after-tax dollars. In this regard, petitioner specifically elected, in August 1994, not to pay the premiums for disability insurance with pre-tax dollars pursuant to “premium conversion”. This election remained in effect throughout 1997. Petitioners did not report on their Federal income tax return the disability benefits received by petitioner in 1997. In the notice of deficiency, respondent determined that such benefits were includable in petitioners’ gross income for thePage: Previous 1 2 3 4 5 6 7 8 9 Next
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