Larry Whittington - Page 7




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          crusades.  FOL had loyal followers, some who attended worship               
          services held regularly in Greenville, and others who attended              
          crusades held regularly in various cities.  Many of FOL's members           
          were not associated with any other religious organization or                
          denomination.  In essence, FOL had the requisite body of                    
          believers, and, therefore, Ray and Larry performed services under           
          the authority of a church.  In addition, Larry and Ray were                 
          "authorized to administer the sacraments, preach, and conduct               
          services of worship" and were ordained ministers of the Gospel.             
          Salkov v. Commissioner, 46 T.C. 190, 194 (1966).                            
               The housing allowances are excludable only to the extent               
          such allowances were authorized, paid, and expended for housing.            
          See sec. 107(2).  Accordingly, Larry is allowed to exclude                  
          $52,000, $25,903, and $25,608, and Ray is allowed to exclude                
          $35,738, $40,500, and $25,733, relating to 1985, 1986, and 1987,            
          respectively.                                                               
          II.  Unreported Income                                                      
               A.  Payments From FOL                                                  
               Respondent determined that Larry's and Ray's travel                    
          reimbursements were taxable income.  Generally, an employee is              
          not required to report reimbursements received from an employer             
          for travel expenses incurred by the employee, for the benefit of            
          the employer, if the employee makes an "adequate accounting" to             
          his employer.  Sec. 1.274-5(e)(2)(i), Income Tax Regs. (requiring           






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