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Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1985 -- $1,200
1990 $5,685 1,421
1991 5,658 234
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. References to petitioner in the singular are to
Henry W. Radde.
After settlement of some issues, the primary issues for
decision are: (1) Whether, for Federal income tax purposes,
petitioner is to be treated as an employee of the United
Methodist Church (hereinafter sometimes referred to as the church
or the Methodist church) or as a self-employed minister, and
(2) whether, for self-employment tax purposes, the stipulated
fair rental value of parsonages provided to petitioners includes
an amount relating to utility and other household expenses of the
parsonages.
FINDINGS OF FACT
Many of the facts have been stipulated and are so found.
When the petition was filed, petitioners resided in Hurst, Texas.
During the years in issue, petitioner worked as an ordained
minister for the United Methodist Church. As such, petitioner
agreed to abide by and practice the precepts contained in the
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Last modified: May 25, 2011