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Petitioner Alfaye Youngblood began employment as a case
manager with the Franklin County Board of Health and Human
Services on July 18, 1988. Petitioner sought counseling to deal
with mental stress after her workload was increased in 1996. In
1997, petitioner took a temporary leave of absence from her
position as case manager. Petitioner was eventually diagnosed as
having permanent mental injury, and her employment ended on April
8, 2003. The parties agree that petitioner’s disability was
employment-related.
On September 10, 1997, petitioner applied to the Ohio Bureau
of Workers’ Compensation for disability benefits. Petitioner
claimed that the increased workload at her job had caused her to
suffer from major depression and panic disorder. Petitioner’s
claim for workers’ compensation benefits was denied because she
had not sustained a physical injury. Petitioner then applied for
disability benefits with the Public Employees Retirement System
of Ohio (PERS). PERS approved petitioner’s application for
benefits on March 23, 1999.
In 1999, petitioner received total payments in the amount of
$51,437. PERS issued a Form 1099-R, Distributions From Pensions,
Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance
Contracts, etc., to petitioner in which it reported a gross
taxable distribution of $51,437. Petitioner excluded the $51,437
from gross income on her 1999 income tax return. Respondent
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