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Larry Whittington
Housing Allowance Travel ECU
Scholarship
Year Salary Authorized Paid Expended1 Reimbursement Tickets2 Pledges3
1985 $88,400 $52,000 $61,600 $57,108 $20,421 -- --
1986 91,000 45,000 40,500 25,903 23,169 $522 $2,000
1987 88,000 45,000 55,500 25,608 20,825 -- 2,000
Ray Whittington
Housing Allowance Travel ECU
Scholarship
Year Salary Authorized Paid Expended1 Reimbursement Tickets2 Pledges3
1985 $88,400 $52,000 $48,100 $35,738 $2,606 -- --
1986 91,000 45,000 40,500 48,247 1,902 $522 $2,000
1987 88,000 45,000 58,000 25,733 4,300 -- 2,000
1 The portion of the allowance expended for housing-related expenses.
2 FOL purchased East Carolina University (ECU) football tickets for
petitioners.
3 FOL made scholarship pledges to ECU on behalf of petitioners.
In 1985, Whittington, Inc., issued three checks payable to
Ray for $1,750 each, and Lovejoy issued six checks payable to
Larry for $1,750 each. In April of 1987, Whittington, Inc.,
issued four checks payable to Ray or his creditors totaling
$21,172.
On their respective Federal income tax returns, Larry
claimed charitable deductions of $6,500, $15,751, and $26,500,
and Ray claimed charitable deductions of $11,500, $28,362, and
$18,300, relating to contributions to FOL in 1985, 1986, and
1987, respectively.
OPINION
I. Parsonage Allowances
Respondent determined that petitioners are not, pursuant to
section 107, entitled to exclude from income parsonage allowances
received from FOL. Section 107 provides that a minister of the
Gospel may exclude from gross income a rental allowance paid to
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