114 T.C. No. 23
UNITED STATES TAX COURT
RICHARD D. WARREN AND ELIZABETH K. WARREN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14924-98. Filed May 16, 2000.
P is a minister of the gospel within the meaning
of sec. 107, I.R.C. The church which employed him
designated most or all of his compensation as a housing
allowance during each of the taxable years in issue.
Ps used the allowance to provide a home for themselves
and their children.
The amount they used to provide a home, and
exclude from income under sec. 107(2), I.R.C., was more
than the fair market rental value of their home. R
contends that Ps’ exclusion under sec. 107(2), I.R.C.,
may not exceed the lesser of the amount Ps used to
provide a home or the fair market rental value of their
home.
Held: The exclusion under sec. 107(2), I.R.C., is
limited to the amount used to provide a home, not the
fair market rental value of the home.
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