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merely performed duties as an administrator, a primarily secular
function.
Finally, we consider whether the temple considered
petitioner its religious leader. We cannot find that it did, as
petitioner failed to present testimony or admissible evidence
establishing that the temple or anyone else viewed him that way.
Accordingly, we find that petitioner failed to demonstrate
that he was a "minister of the gospel" as specified in the
regulations and case law. As a judicial body we are loath to
evaluate ecclesiastical authority in the various religious
disciplines. We emphasis that our opinion is based on the record
before us, and our finding should not diminish the importance of
petitioner's contributions to his community.
Designation of Rental Allowance
To qualify for the parsonage exclusion, the amount paid to a
minister, to rent or otherwise provide a home, must be designated
as rental allowance pursuant to official action taken in advance
of such payment. Sec. 1.107-1(b), Income Tax Regs. The above
regulation states that a designation may be evidenced in an
employment contract, in minutes of or in a resolution by a
qualified organization, or in any appropriate instrument
evidencing such official action. Without official designation,
no exclusion is allowable under section 107. See Eden v.
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