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HAYNES V. UNITED STATES, 353 U. S. 81 (1957)

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U.S. Supreme Court

Haynes v. United States, 353 U.S. 81 (1957)

Haynes v. United States

No. 257

Argued March 5, 1957

Decided April 1, 1957

353 U.S. 81


Pursuant to a comprehensive "Plan for Employees' Pensions, Disability Benefits and Death Benefits," which a corporation had had in force for many years and copies of which were furnished to each employee, the corporation paid one of its employees $2,100 in sickness disability benefits, which was equivalent to his salary for a year, during which time the employee had been sick and unable to work.

Held: under § 22(b)(5) of the Internal Revenue Code of 1939, such income of the employee was exempt from income tax as an amount received through "health insurance." Pp. 353 U. S. 82-86.

(a) Broadly speaking, "health insurance" is an undertaking by one person for reasons satisfactory to him to indemnify another for losses caused by illness, and the plan here involved comes within this meaning. P. 353 U. S. 83.

(b) A different result is not required by the facts that, under the corporation's plan, the employees paid no fixed periodic premiums, there was no definite fund created to assure payment of disability benefits, and the amount and duration of the benefits varied with the length of service. Pp. 353 U. S. 83-84.

(c) There is nothing in the language or legislative history of § 22(b)(5) which limits the term "health insurance" to particular forms of insurance conventionally made available by commercial companies, nor does there appear to be any other reason for so limiting it. Pp. 353 U. S. 84-85.

233 F.2d 413, reversed. chanroblesvirtualawlibrary

Page 353 U. S. 82

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