Oscar Haimowitz - Page 8

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          organizational than religious in nature and did not require                 
          performance from one who held ministerial authority.                        
               Equally revealing, however, were the religious rites and               
          ceremonies petitioner did not perform.  Petitioner admitted that            
          he never fulfilled the role of either rabbi or cantor.  The                 
          record displays his lack of such responsibility.  Petitioner                
          assumed responsibility over the Bar and Bat Mitzvah students only           
          in the last week or two of their training and only to enhance the           
          efforts of the rabbi and cantor.  The rabbi and cantor, however,            
          held the main parochial responsibilities for the students'                  
               Further, petitioner acted as the marriage ceremony director            
          and participated in wedding ceremonies as a witness.  His                   
          responsibilities as director, however, were mostly secular in               
          nature.  While petitioner participated in wedding ceremonies, he            
          never officiated.  Further, petitioner assisted the rabbi with              
          various functions during religious services.  It was the rabbi,             
          however, not petitioner, who actually led those services for                
          which petitioner assisted.  Finally, although petitioner visited            
          and conducted services for mourners, he, presumably, did not                
          officiate at the funerals.                                                  
               As illustrated above, with the sole exception of conducting            
          services for mourners, petitioner did not regularly perform those           
          duties that ministers of the Jewish faith customarily perform.              

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