Joey, age 40, is the president of Alpha Enterprises. Joey is insured under a group life permanent policy that provides him with retirement income at the earlier of age 65 or after 30 years of service. To receive this benefit, however, he must be an employee of the company at his retirement date. All premiums on the policy are paid by Alpha Enterprises. Is the cost of the permanent coverage for Joey taxable, and why or why not?

A)

Yes, because Joey is provided with retirement income

B)

No, because Joey does not pay premiums on the policy

C)

Yes, because Joey is an officer of the corporation

D)

No, because Joey is not substantially vested in the policy