Richard G. and Anne C. Greene - Page 2

               Respondent determined a deficiency in petitioners' Federal             
          income tax for the taxable year 1992 in the amount of $998.                 
               The sole issue for decision is whether petitioner Richard G.           
          Greene, an Assemblies of God missionary, was an employee or an              
          independent contractor in 1992.  The answer will determine                  
          whether his expenses constitute deductible business expenses on             
          Schedule C under section 62(a)(1), or are miscellaneous itemized            
          deductions allowable on Schedule A under section 67 to the extent           
          that they exceed 2 percent of petitioners' adjusted gross income.           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  Petitioners are husband and wife and resided in                     
          Bangladesh at the time that their petition was filed with the               
          1.   General Background                                                     
               Petitioner Richard G. Greene (petitioner) was licensed and             
          ordained as a minister of the National Assemblies of God Church             
          (the National Church) in May 1987 and May 1989, respectively.               
          Petitioner pastored an Assemblies of God church in Leesville,               
          Louisiana, at least from the time he became licensed until                  
          December 1990, at which time he resigned as a pastor in order to            
          pursue a career as a missionary.  During 1992, petitioner                   
          performed services as an Assemblies of God missionary.                      

          2 Pursuant to sec. 7482(b)(2), the parties stipulated that                  
          the venue for purposes of an appeal from this decision will be              
          the U.S. Court of Appeals for the District of Columbia Circuit.             

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011