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premiums.1 Based on these expenditures, petitioners excluded
from income on their 1993 return all of petitioner’s compensation
from the church and reported as income $9,866 in 1994 and $19,654
in 1995.
The amounts remaining in dispute are the differences
between the rental values of petitioners’ home and the amounts
petitioners excluded from their returns. The following table
summarizes relevant financial information:
Amount in dispute
(i.e., amount
Taxable Compensation HousingAmount excludedRental valueexcluded less rental
year received expenditures from incomeof home value of home)
1993 $77,663 $77,663 $77,663 $58,061 $19,602
1994 86,175 76,309 76,309 58,004 18,305
1995 99,653 84,278 79,999 59,479 20,520
Petitioners reported that petitioner had net Schedule C,
Profit and Loss From Business, income from his tape and book
ministry of $183,635 in 1993, $217,770 in 1994, and $221,401 in
1995, and total income (not including the housing allowance paid
by the church to the extent excluded by petitioners from their
gross income) of $187,652 for 1993, $219,919 for 1994, and
$241,238 for 1995.2
1 The parties stipulated that all of these expenditures
were used to provide housing.
2 Although the record is silent as to why petitioners
excluded only $79,999 when they spent $84,278 on housing for
1995, we infer that it was because the church designated an
$80,000 housing allowance for the church’s 1996 fiscal year.
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