Oscar Haimowitz - Page 4

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               Petitioner additionally performed as the temple's marriage             
          ceremony director.  Petitioner would meet with engaged couples to           
          discuss wedding preparations.  Petitioner's advice was mostly               
          organizational in nature and related to the specific details of             
          planning a wedding.  Petitioner frequently participated in the              
          wedding ceremony as a witness to the contract, but he never                 
          officiated.                                                                 
               Petitioner also assisted the rabbi with various tasks during           
          the religious services.  This included the duty of assigning                
          certain honors and responsibilities to congregants who performed            
          these tasks during services.  Petitioner also performed the                 
          following other activities for the temple:  He managed cemetery             
          lots that the temple made available to its congregants; he                  
          visited and conducted services for mourners; and he provided                
          weekly speakers for senior citizens.                                        
               In 1970, petitioner began paying into an "annuity program"             
          provided by the temple.  Petitioner provided little detail                  
          surrounding the plan or his employment relationship with the                
          temple, other than stating that he contributed 4 percent of his             
          yearly salary and the temple contributed 7 percent.  The pension            
          income at issue was derived from this plan.                                 
               In 1992, petitioner received $3,705 in pension income, but             
          excluded that amount from gross income.  In the notice of                   







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