- 6 - Respondent contends that the pension income should not be excluded from petitioner's 1992 gross income for the reason that, at the time petitioner contributed to the pension plan, he was not a "minister of the gospel" for section 107 purposes. Respondent also contends that the pension income was not properly designated by the temple as a parsonage allowance, as required. Respondent, however, does not question whether the funds were actually used for housing or whether the provisions of section 107 have applicability to pension income. See Rev. Rul. 75-22, 1975-1 C.B. 49; Rev. Rul. 63-156, 1963-2 C.B. 79. Petitioner does not claim that he was a rabbi or cantor. Rather, petitioner suggests that he qualified as a "minister of the gospel" because he performed duties as a "religious functionary" for the temple. Minister of the Gospel The Internal Revenue Code does not define the phrase "minister of the gospel", and the statute's legislative history contains no clear meaning of the term. The regulations define only what a minister does, but not what a minister is. Section 1.107-1(a), Income Tax Regs., states that in order to qualify for the exclusion, the home or rental allowance must provide remuneration for services which are ordinarily the dutiesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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