imputed income and gross up

[k man]

client wants to exclude fringe benefits, in this case a use of an automobile. this generates imputed income. they will eclude this from the definition of compensation. however, they also give the client a gross up to compensate for the taxes that result from the imputed income. is the gross up also excludable as a fringe benefit? plan document allows employer to exclude cash and non cash fringes from the definition of comp.