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In computing his net earnings from self-employment,
petitioner must include all his earnings from his ministry,
including his parsonage allowance, and may claim the deductions
“allowed by chapter 1 of the Code which are attributable to such
trade or business”. Sec. 1.1402(a)-1(a)(1), Income Tax Regs.
Because a portion of petitioner’s deductions, $10,522, is
allocable to his parsonage allowance, and is disallowed as a
deduction by section 265, it may not be deducted in computing
petitioner’s net earnings from self-employment. Id.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011