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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
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