Geoff Eyler & Audrey Eyler - Page 9




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               SEC. 105.  AMOUNTS RECEIVED UNDER ACCIDENT AND HEALTH                  
                         PLANS.                                                       
                  *       *       *       *       *       *       *                   
                         (b) Amounts Expended for Medical Care.--                     
                    * * * gross income does not include amounts                       
                    referred to in subsection (a)[11] if such                         
                    amounts are paid, directly or indirectly, to                      
                    the taxpayer to reimburse the taxpayer for                        
                    expenses incurred by him for the medical care                     
                    (as defined in section 213(d)) of the tax-                        
                    payer, his spouse, and his dependents                             
                    * * *.[12]                                                        
               Section 106(a) on which petitioners also appear to rely                
          provides:                                                                   
               SEC. 106.  CONTRIBUTIONS BY EMPLOYER TO ACCIDENT AND                   
               HEALTH PLANS.                                                          
                         (a) General Rule.-- Except as otherwise                      
                    provided in this section, gross income of an                      
                    employee does not include employer-provided                       
                    coverage under an accident or health plan.                        
          A contribution by an employer to an accident or health plan                 
          described in section 106 includes a payment that such employer              


               11Sec. 105(a) provides:                                                
                    (a) Amounts Attributable to Employer                              
               Contributions.--Except as otherwise provided in this                   
               section, amounts received by an employee through acci-                 
               dent or health insurance for personal injuries or                      
               sickness shall be included in gross income to the                      
               extent such amounts (1) are attributable to contribu-                  
               tions by the employer which were not includible in the                 
               gross income of the employee, or (2) are paid by the                   
               employer.                                                              
               12For purposes of sec. 105(b), expenses for medical care               
          include amounts paid as premiums for insurance covering medical             
          care referred to in sec. 213(d)(1)(A) and (B).  Sec.                        
          213(d)(1)(D).                                                               





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