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services that petitioner performed as a licensed local pastor
during 1983 and 1984 in order to determine whether such services
constituted the performance of services as a licensed minister
within the meaning of section 1402.
An individual acting pursuant to authority derived from his
or her status as a duly ordained, commissioned, or licensed
minister of a church, who in the exercise of his or her ministry:
(1) Presides over the ministration of sacerdotal functions; (2)
conducts religious worship; and (3) participates in the control,
conduct, and maintenance of religious organizations (including
the religious boards, societies, and other integral agencies of
such organizations), under the authority of a religious body
constituting a church or church denomination, performs services
as a minister within the meaning of section 1402. See Wingo v.
Commissioner, supra at 931; sec. 1.1402(c)-5(b)(2), Income Tax
Regs.
Set against these criteria, and taking into account the
respective positions of the parties, we examine what petitioner
did as a licensed local pastor in 1983 and 1984 in order to
determine whether the services he performed as such constituted
the services of a "duly ordained, commissioned, or licensed
minister" within the meaning of section 1402.
As a licensed local pastor, petitioner was authorized by the
Church to preside over the ministration of sacerdotal functions,
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