Johnny J. and Brenda D. Young - Page 3

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               Respondent determined a deficiency of $13,363 in                       
          petitioners’ Federal income tax for 2000 and an accuracy-related            
          penalty under section 6662 of $2,672.60.  Petitioners concede               
          that Johnny J. Young (petitioner) received wages of $36,000, and            
          self-employment income of $21,438.  Respondent concedes that                
          petitioners have substantiated that the following $24,982 of                
          expenses were paid in the exercise of petitioner’s ministry:  (a)           
          Automobile expenses of $7,000, (b) books of $3,000,                         
          (c) advertising of $377, (d) office expenses of $5,000, and (e)             
          trips of $9,605.  Respondent concedes that petitioners are                  
          entitled to deductions for mortgage interest of $50,825 and                 
          charitable contributions of $22,587.  Respondent also concedes              
          that petitioners are not liable for the accuracy-related penalty            
          under section 6662.  The issues remaining for decision are                  
          whether petitioners:  (a) Must allocate expenses incurred in the            
          exercise of petitioner’s ministry between exempt and nonexempt              
          income, and (b) have additional income subject to self-employment           
          tax.                                                                        
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received in evidence              
          are incorporated herein by reference.  At the time the petition             
          was filed, petitioners resided in Los Angeles, California.                  
               Petitioner was ordained as a minister by the Church of God             






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