- 11 -
Commissioner, 41 T.C. 605, 607 (1964); Mosley v. Commissioner,
T.C. Memo. 1994-457.
Petitioner failed to demonstrate that the temple properly
designated the pension income as a parsonage allowance.
Completely missing from the record were details of the employment
arrangement in which he and the temple were engaged. In fact,
petitioner presented no evidence which even tangentially relates
to the notion of official designation.
Accordingly, we find that petitioner is not entitled to
exclude the pension income from his 1992 gross income under the
parsonage exclusion found in section 107(2).
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011