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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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