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
Court.2
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.
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