Oscar Haimowitz - Page 10

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          merely performed duties as an administrator, a primarily secular            
               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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