Richard G. and Anne C. Greene - Page 17

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          rather, he has consulted fellow missionaries when he has had                
          questions about missionary activities.                                      
          4.   Petitioners' Tax Return and the Notice of Deficiency                   
               The National Church issued petitioner Form 1099-MISC.  Such            
          Form reflected nonemployee compensation for services rendered and           
          indicated that Federal income tax was not withheld from that                
          compensation.  Petitioner reported his missionary-related income            
          and expenses on Schedule C.                                                 
               Respondent does not challenge the amount of petitioners'               
          claimed business expenses.  Rather, in her notice of deficiency,            
          respondent determined that petitioner was an employee rather than           
          an independent contractor in 1992.  As a result of this                     
          determination, respondent reclassified the expenses claimed by              
          petitioner on his Schedule C as Schedule A expenses deductible              
          only as miscellaneous itemized deductions, subject to the 2-                
          percent limitation under section 67.                                        
                              ULTIMATE FINDING OF FACT                                
               Petitioner, an endorsed Assemblies of God missionary, was an           
          independent contractor in 1992.                                             
               Petitioners contend that petitioner was an independent                 
          contractor and, as such, was entitled to deduct the full amount             
          of his business expenses on Schedule C pursuant to section 162.             
          Respondent determined that petitioner was an employee during                
          1992.  Petitioners bear the burden of proving that respondent's             

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