Kenneth & Linda J. Logie - Page 3

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          was associate minister of the Interdenominational Gospel Chapel             
          in Oakland, California.  The chapel held services five times a              
          week in a rented building in Oakland and had approximately 100              
          members.                                                                    
               Mr. Logie's Wage and Tax Statement (Form W-2) from the                 
          Interdenominational Gospel Chapel for the 1994 tax year listed              
          wage income in the amount of $548 and listed other income in the            
          amount of $4,712, which was described as "Parsonage".  Mrs.                 
          Logie's Form W-2 from the Interdenominational Gospel Chapel for             
          the 1994 tax year listed wage income in the amount of $20,276 and           
          listed other income in the amount of $10,000, which was described           
          as "Parsonage".                                                             
               Petitioners reported their income for 1994 on a joint Form             
          1040, which showed no tax liability.  Petitioners excluded from             
          gross income those amounts listed and described on their Forms              
          W-2 as "Parsonage", totaling $14,712, and separately deducted               
          this same amount as an adjustment to income.  On the Schedule C             
          attached to their return, petitioners reported a loss of $1,143             
          from a business described as "Linda Logie Distributor Matol                 
          Botanical."  On the Schedule C, petitioners claimed cost of goods           
          sold in the amount of $10,251.  This amount included supplies               
          expenses in the amount of $1,400, which was separately and                  
          duplicatively deducted on line 22 of the Schedule C.  Petitioners           
          also claimed on their Schedule C utilities expenses for telephone           





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