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We hold that he is.
Adjustments relating to the taxable portion of petitioner’s
Social Security benefits, miscellaneous itemized deductions, and
self-employment tax are purely mechanical matters, the resolution
of which is dependent on our disposition of the disputed issues.
Background
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Rancho Mirage, California, at the
time that his petition was filed with the Court.
A. Petitioner and His Background
Petitioner was born in May 1929, and he turned 67 in 1996.
Petitioner is a former account executive (stockbroker) for
E.F. Hutton Group, Inc. Petitioner retired from E.F. Hutton
sometime prior to 1996.
In 1989, petitioner acquired the title of “bishop” from
Universal Life Church, Inc., of Modesto, California. A few years
later, in 1994, petitioner purportedly completed a “non-secular
course of study” and became a “lymphologist”. Petitioner’s
“certificate” from “The International Academy of Lymphology”
recites, in part, that “Based on the United States Supreme Court
and Federal District Court guidelines, the right to teach and
practice this Non-Secular Science anywhere in the United States
comes from God and is PROTECTED BY THE CONSTITUTION IN THE FIRST
AMENDMENT’S FREE EXERCISE CLAUSE.”
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