- 9 -
See Silverman v. Commissioner, 57 T.C. 727, 731 (1972), affd. in
an unreported case 32 AFTR2d 73-5379, 73-2 USTC par. 9546 (8th
Cir. 1973) (a cantor's performance of the following duties were
considered ministerial: Conducting religious worship,
administering sacerdotal functions, performing marriages,
officiating at funerals, leading services at houses of mourning,
and directing organizations within the congregation); Salkov v.
Commissioner, 46 T.C. 190, 195-196 (1966).
We next consider whether petitioner was ordained,
commissioned, or licensed in his capacity as "religious
functionary". The record demonstrates that he was not.
Petitioner admitted at trial that he was not an ordained rabbi or
a commissioned cantor. The fact that petitioner was recognized
as a Fellow in Synagogue Administration is irrelevant to the
above determination. First, petitioner did not hold this title
while he performed his duties with the temple. Rather, he
received this honor sometime around 1987, about 7 years after he
left the temple. Second, even if petitioner had received this
honor while performing services for the temple, this title would
not have established that petitioner was ordained, commissioned,
or licensed as a recognized religious official of the Jewish
religion. Rather, as the words Fellow in Synagogue
Administration suggest, the designation reflects that petitioner
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