Stephen Hayden - Page 4

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          plus the insured employee’s earnings over his/her pre-disability            
          earnings.                                                                   
               The maximum benefit period was determined by the insured               
          employee’s age at disability, as follows:                                   
               Age at Disability        Maximum Benefit Period                        
               Less than 60             To age 65                                     
               60                       60 mos.                                       
               61                       48 mos.                                       
               62                       42 mos.                                       
               63                       36 mos.                                       
               64                       30 mos.                                       
               65                       24 mos.                                       
               66                       21 mos.                                       
               67                       18 mos.                                       
               68                       15 mos.                                       
               69 and over              12 mos.                                       
               If a disability was caused by mental illness, alcoholism, or           
          drug abuse, the benefit period generally could not exceed 24                
          months.4                                                                    
               Calera paid the premium under the UNUM policy.  Petitioner was         
          not required to pay any portion of the premium or to make                   
          contributions in order to be covered under the UNUM policy.                 
          Petitioner was not required to include (and did not include) any            
          portion of the premium payment in his gross income.                         
               In December 1994, petitioner suffered a severe neurological            
          impairment that prevented him from engaging in any gainful                  


               4    If an insured employee continued to be disabled and               
          became confined in a hospital or institution after the 24-month             
          period and for at least 14 consecutive days, the monthly benefit            
          was payable during the confinement.                                         





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