Henry W. Radde and Susan K. Radde - Page 2

                                        - 2 -                                         
                                             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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