- 2 -
entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined deficiencies in petitioners’ Federal
income taxes of $9212 for 2000 and $1,082 for 2001. The issues
for decision are:
1. Whether petitioners, husband and wife, had an employer-
employee relationship. We find that they did.
2. Whether petitioners may exclude from gross income
medical benefits of $3,279 in 2000 and $4,539 in 2001 paid by an
employer-spouse to an employee-spouse. We find that they may.
3. Whether petitioners may deduct from gross income medical
benefits of $3,279 in 2000 and $4,539 in 2001 paid by an
employer-spouse to an employee-spouse. We find that they may.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Petitioners resided in
Rollingstone, Minnesota, at the time they filed the petition.
Maureen Speltz
Petitioner Maureen Speltz (Mrs. Speltz) has operated a sole
proprietorship daycare business in petitioners’ home since 1982.
Mrs. Speltz has an elementary education degree, and she has been
2All monetary amounts have been rounded to the nearest
dollar.
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