Roosevelt Wallace - Page 14




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          policy”.  Webster’s Third New International Dictionary 204                  
          (2002).                                                                     
               The relevant definitions in The American Heritage Dictionary           
          of the English Language are similar, but with some variation in             
          the second case, viz:  “(2) A payment made or an entitlement                
          available in accordance with a wage agreement, an insurance                 
          policy, or a public assistance program.”  The American Heritage             
          Dictionary of the English Language 168 (4th ed. 2000).                      
               Both Merriam-Webster’s Collegiate Dictionary and Merriam-              
          Webster’s Online Dictionary include the following definition:  “a           
          service (as health insurance) or right (as to take vacation time)           
          provided by an employer in addition to wages or salary”.                    
          Merriam-Webster’s Collegiate Dictionary 114 (11th ed. 2003) and             
          Merriam-Webster’s Online Dictionary, http://aolsvc.merriam-                 
          webster.aol.com/mwwod-aol.htm (last visited Feb. 26, 2007).                 
               Those definitions are instructive.  We conclude the                    
          following:  The term “benefit” is commonly understood to include            
          things both tangible and intangible.  Independence and vocational           
          functioning are among the intangible benefits intended for                  
          participants in the CWT program.  Although the term “benefit” is            
          not synonymous with the term “payment”, many payments are                   
          benefits, including payments that constitute items of gross                 
          income, e.g., fringe benefits, pensions and annuities.  See sec.            
          61(a)(1) (fringe benefits), (9) (annuities), (11) (pensions).               







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