Vincent Michael Coomes - Page 6

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          income taxes on his income from self-employment, including self-            
          employment taxes under section 1401, for each of the years at               
          issue.  Petitioner is, however, entitled to the deductions                  
          stipulated by the parties.                                                  
               With respect to the interest and dividend income petitioner            
          received, there is no question that these funds must be included            
          in petitioner’s gross income as provided by section 61(a)(3) and            
          (7).  See also secs. 1.61-7(a), 1.61-9(a), Income Tax Regs.                 
          Petitioner, in fact, conceded that he received interest income in           
          1997 and 1998 and dividend income in 1998.                                  
               A.  Additions to Tax                                                   
               Petitioner has conceded that he owes additions to tax under            
          sections 6651(f) and 6654.  We need not engage in a discussion              
          regarding these additions since petitioner concedes their                   
          applicability.                                                              
               B.  Petitioner’s Asserted Vow of Poverty                               
               The issue raised is whether petitioner’s asserted vow of               
          poverty exempts the income he received for the years at issue               
          from gross income.  In short, it does not.                                  
               Petitioner contends that his taking a vow of poverty                   
          assigning all income to a religious institution provides him with           
          an exemption from Federal income taxes for all years at issue.3             

               3We see no reason to address whether the Universal Christian           
          Church is a sec. 501(c)(3) organization since petitioner did not            
                                                             (continued...)           





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