- 2 -
Arthur A. Oshiro, for petitioners.
T. Ian Russell, for respondent.
OPINION
COLVIN, Judge: Respondent determined the following
deficiencies and accuracy-related penalties with respect to
petitioners’ Federal income taxes for taxable years 1993, 1994,
and 1995:
Sec. 6662(a)
Year Deficiency Penalty
1993 $11,932 $2,386
1994 18,061 3,612
1995 16,080 3,216
Petitioner is a minister of the gospel within the meaning of
section 107. After concessions, the sole issue for decision is
whether the amount of petitioner’s housing allowance compensation
that is excludable from gross income under section 107(2) is
limited to the amount used to provide a home, as petitioners
contend, or to the lesser of that amount or the fair market
rental value of the home, as respondent contends. We hold that
it is limited to the amount used to provide a home.
Unless otherwise indicated, section references are to
sections of the Internal Revenue Code in effect for the years in
issue, and Rule references are to the Tax Court Rules of Practice
and Procedure. References to petitioner are to Richard D.
Warren.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011