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C. Petitioner’s Compensation From the Saddleback Valley
Community Church
Each year, before the fiscal year began, the church’s
trustees met to designate the amount of compensation to be paid
to each of its ministers. The trustees also allocated these
amounts between salary and housing allowances. In 1992, the
church adopted a fiscal year ending May 31. For the short year
from January 1 to May 31, 1993, petitioner received $42,496, all
of which the trustees of the church designated as a housing
allowance. For the fiscal year ending May 31, 1994, the trustees
approved compensation of $85,000 for petitioner and designated
the full amount as a housing allowance. For the fiscal year
ending May 31, 1995, the trustees approved compensation of
$100,000, all of which they designated as a housing allowance.
For the fiscal year ending May 31, 1996, the trustees approved
compensation of $100,000 and allocated $20,000 for salary and
$80,000 for a housing allowance.
Petitioner received the following amounts from the church as
compensation for the calendar years in issue: $77,663 for 1993,
$86,175 for 1994, and $99,653 for 1995. Petitioners used $77,663
in 1993, $76,309 in 1994, and $84,278 in 1995 to provide a home
for themselves and their children by paying expenses for
mortgage, utilities, furnishings, landscaping, repairs, and
maintenance and real property taxes and homeowner’s insurance
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