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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 duties
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