Johnny J. and Brenda D. Young - Page 6

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               Section 1.265-1(c), Income Tax Regs., provides:                        
                    (c) Allocation of expenses to a class or classes                  
               of exempt income.  Expenses and amounts otherwise                      
               allowable which are directly allocable to any class or                 
               classes of exempt income shall be allocated thereto;                   
               and expenses and amounts directly allocable to any                     
               class or classes of nonexempt income shall be allocated                
               thereto.  If an expense or amount otherwise allowable                  
               is indirectly allocable to both a class of nonexempt                   
               income and a class of exempt income, a reasonable                      
               proportion thereof determined in the light of all the                  
               facts and circumstances in each case shall be allocated                
               to each.                                                               
               The issue of whether petitioner’s ministry expenses are                
          deductible against his tax-exempt parsonage income has been                 
          examined by this Court before.  In McFarland v. Commissioner,               
          supra, we held that ministry expenses incurred by the taxpayer              
          were indirectly allocable to a class of nonexempt income and a              
          class of exempt income when the taxpayer’s only business activity           
          was his ministry and he received both taxable compensation and              
          tax-exempt parsonage allowance.  Likewise, in Dalan v.                      
          Commissioner, supra, the Court held that section 265(a)(1) barred           
          the deduction of the taxpayer’s ministry expenses to the extent             
          the expenses were allocable to his tax-exempt ministry income               
          even though the taxpayer had nonexempt income from his job as a             
          guidance counselor.  See Deason v. Commissioner, supra (minister            
          taxpayer denied deduction for automobile business expenses when             
          virtually all income earned during year was tax-exempt parsonage            
          allowance under section 107.)                                               
               Petitioner’s circumstances are not factually distinguishable           





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