Leo and Shawn M. Stephens - Page 3




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          and this opinion shall not be treated as precedent for any other            
          case.  The issue for decision is whether, pursuant to section               
          162(a), petitioners are entitled to deduct expenses related to              
          employee benefit programs.                                                  
                                     Background                                       
               Petitioner Leo Stephens and his wife Shawn Stephens operated           
          a custom harvesting business, Stephens Family, LLC, that                    
          consisted of cutting, hauling, and selling grain (the harvesting            
          business).  Through a joint venture with Mrs. Stephens’s mother,            
          Clair Schrock, Mr. Stephens also operated a farm on which they              
          grew various crops and raised 30 to 40 head of cattle.                      
               In January 1995, Mr. Stephens enrolled in a health plan                
          through Blue Cross/Blue Shield of Kansas.  Mr. Stephens was the             
          named policyholder and his family (i.e., his spouse and his four            
          children) was covered under the plan.  Mr. Stephens paid the plan           
          premiums out of a joint bank account he owned with Mrs. Stephens.           
          In December 1998, Mr. Stephens, through AgriPlan/BizPlan, adopted           
          an employer-provided accident and health plan for employees.  The           
          plan provided for full reimbursement for health insurance costs             
          to eligible employees and their families.  In addition, eligible            
          employees qualified for reimbursement of up to $15,000 for out-             
          of-pocket medical expenses.  To be reimbursed, eligible employees           
          were required to submit a transmittal form to AgriPlan/BizPlan              








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