Leo and Shawn M. Stephens - Page 4




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          indicating the amount the employee paid for health insurance and            
          out-of-pocket medical expenses during the year.  AgriPlan/BizPlan           
          would then process the transmittal form and issue a statement to            
          the employer stating the amount the employer should reimburse the           
          eligible employee.                                                          
               On January 1, 1999, Mrs. Stephens entered into an employment           
          agreement with Mr. Stephens.  Mrs. Stephens agreed to do                    
          bookkeeping for the businesses, run errands, prepare meals for              
          the staff, answer phones, and do general field work and customary           
          duties.  The employment agreement specified that Mrs. Stephens              
          would be paid $2,000 annually and be an eligible enrollee under             
          the AgriPlan/BizPlan.                                                       
               In 2001, Mrs. Stephens worked 1,172 hours for the harvesting           
          business and the farm and was issued a Form W-2, Wage and Tax               
          Statement (Form W-2).  Thereafter, she submitted an employee                
          benefit expense transmittal form to AgriPlan/BizPlan claiming               
          that, in 2001, she had paid $8,650 for medical expenses.  Of this           
          total, $4,978 was attributable to the health insurance premiums             
          relating to the Blue Cross/Blue Shield plan, and $3,672 was                 
          attributable to out-of-pocket medical expenses.  These expenses             
          were paid out of petitioners’ joint bank account, and petitioners           
          were not reimbursed.  On the Schedule F, Profit or Loss from                










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