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paid, directly or indirectly, to Ms. Frahm certain amounts for
premiums for various insurance policies covering herself, her
spouse Mr. Frahm, and/or both of them.31 Respondent concedes the
deductibility under section 162(a) of the amounts of such premi-
ums that Mr. Frahm, as Ms. Frahm’s employer, paid, directly or
indirectly, to Ms. Frahm for the insurance policies issued in her
name and covering only her. Respondent disputes only the deduct-
ibility under section 162(a) of the amounts of such premiums that
Mr. Frahm, as Ms. Frahm’s employer, paid, directly or indirectly,
to Ms. Frahm for the insurance policies issued in his name and
covering only him or covering him and her.32
We consider first the respective amounts that Mr. Frahm, as
Ms. Frahm’s employer, paid during the years at issue directly to
Ms. Frahm in order to reimburse her for the premiums that she
paid during those years for the policies issued in her spouse’s
(i.e., Mr. Frahm’s) name. On the record before us, we find that,
pursuant to the AgriPlan/AgriBiz medical reimbursement plan, Mr.
Frahm, as Ms. Frahm’s employer, paid directly to Ms. Frahm
certain amounts (1) during 2000 in order to reimburse her for the
premiums that she paid during that year for Mr. Frahm’s Wellmark
Plan C policy, (2) during 2001 in order to reimburse her for the
31Respondent does not dispute that the AgriPlan/AgriBiz
medical reimbursement plan constitutes a health plan described in
sec. 105.
32See supra note 25.
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Last modified: March 27, 2008