Vincent Michael Coomes - Page 7

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          Other than his testimony, petitioner has not offered any evidence           
          to substantiate his asserted vow of poverty.  Even assuming                 
          petitioner took such a vow, his argument fails.                             
               Merely taking a vow of poverty does not necessarily exempt a           
          taxpayer from Federal income taxes, including self-employment               
          taxes.  This Court has held that when “secular services are                 
          rendered by individuals, income received by them in an individual           
          capacity and not on behalf of a separate and distinct principal             
          is taxable to the individuals.”  Yoshihara v. Commissioner, T.C.            
          Memo. 1999-375; Stephenson v. Commissioner, 79 T.C. 995 (1982),             
          affd. 748 F.2d 331 (6th Cir. 1984); McGahen v. Commissioner, 76             
          T.C. 468, 478-479 (1981), affd. without published opinion 720               
          F.2d 664 (3d Cir. 1983); see also sec. 1.1402(c)-5(a)(2), Income            
          Tax Regs.                                                                   
               Petitioner has offered nothing to support that any of the              
          income he received was received on behalf of a separate and                 
          distinct principal.  It is also patently obvious that the                   
          telephone services petitioner provided were secular.                        
          Accordingly, we find that petitioner is liable for Federal income           
          taxes on the compensation he earned and on the interest and                 
          dividend income he received.                                                

               3(...continued)                                                        
          assert at trial or on brief that income assigned to the Universal           
          Christian Church qualified for a charitable deduction under sec.            
          170.  Additionally, petitioner did not establish there was a                
          transfer of funds to a religious charity.                                   





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