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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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