How are vacation benefits "qualified benefits" under Section

[Guest Jordan]

Can anyone briefly explain how vacation benefits can be considered a "qualified benefit" under Code Section 125? The tax management portfolio on cafeteria plans makes the statement they are without attribution. Since Section 125 defines a qualified benefit as any benefit which with Section 125 is not includible in gross income by reason of an express provision of chapter 1 of the Code (with certain exclusions). Similarly, on what statutory basis do the proposed regulations govern vacation programs. I could see vacation days as a taxable benefit under 125, like cash, but not as a nontaxable benefit.