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benefits Mr. Cotler received in 1997 and 1998 are excludable from
income under section 104(a)(3).
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulated facts and the attached exhibits are incorporated
herein by this reference. At the time he filed the petition, Mr.
Cotler resided in Hollywood, Florida.
Since 1974, Mr. Cotler was a practicing attorney in the
State of Florida. Mr. Cotler was a shareholder in Cotler &
Baseman, P.A. (the firm).2 At all times, Mr. Cotler was either a
99-percent or a 100-percent shareholder of the firm.
Beginning on November 1, 1993, the firm held a long-term
group disability insurance policy with Standard Insurance Company
(Standard). The firm wrote the checks to pay the premiums on the
Standard policy. The portion of the Standard disability monthly
premium attributable to Mr. Cotler was $81 per month.
In 1996, Mr. Cotler began experiencing constant and severe
headaches, which were diagnosed as chronic intractable headaches.
The headaches left Mr. Cotler unable to focus for long periods,
unable to work, and caused the firm to struggle. After
traditional medicine did not alleviate his pain, Mr. Cotler
traveled to Chicago and Italy to receive alternative medical
2 At some point, the firm was known as Richard S. Cotler,
P.A.
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