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.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