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for petitioner Rosemary Snorek (Mrs. Snorek) are fully deductible
under section 162(a)2 or only 60 percent deductible under section
162(l). We hold that they are 60 percent deductible.
Background
This case was submitted fully stipulated pursuant to Rule
122, and the facts are so found. The stipulation of facts and
accompanying exhibits are incorporated by this reference.
Petitioners resided in Owatonna, Minnesota, at the time they
filed the petition.
Mrs. Snorek operated a sole proprietorship upholstery
business, Snorek Upholstery, during 2001. That year, Snorek
Upholstery executed an adoption agreement to provide a medical
reimbursement plan for eligible employees through an organization
called AgriPlan/BizPlan (the plan). Eligible employees under the
plan would be fully reimbursed by Snorek Upholstery for health
insurance costs for themselves and their immediate family and
reimbursed up to $3,000 for other out-of-pocket medical expenses.
To be reimbursed, an eligible employee was required to submit a
transmittal form to AgriPlan/BizPlan noting the amount the
eligible employee paid or incurred for health insurance and out-
of-pocket medical expenses during the year. AgriPlan/BizPlan
2All section references are to the Internal Revenue Code in
effect for 2001, and all Rule references are to the Tax Court
Rules of Practice and Procedure, unless otherwise indicated.
Amounts are rounded to the nearest dollar.
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Last modified: May 25, 2011