Schuster v. Commissioner
United States Tax Court
Petitioner, a nurse-practitioner, was a member of a religious order of the Roman Catholic Church. She sought and was offered a position with a Federal agency that assigns health care professionals to work in regions lacking adequate medical services. After receiving approval from her Order, petitioner accepted the position. Pursuant to her vow of poverty, petitioner endorsed all of her paychecks over to her Order.
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Petitioner, a nurse-practitioner, was a member of a religious order of the Roman Catholic Church. She sought and was offered a position with a Federal agency that assigns health care professionals to work in regions lacking adequate medical services. After receiving approval from her Order, petitioner accepted the position. Pursuant to her vow of poverty, petitioner endorsed all of her paychecks over to her Order. Held: Petitioner's wages were earned in her individual capacity, and not as an agent of the Order. Her wages are therefore subject to taxation.
1Opinion of the Court
Wilbur, Judge:
Respondent determined a deficiency in petitioner’s 1980 Federal income tax in the amount of $1,529. The sole issue for decision is whether compensation earned by petitioner while she was a member of a religious order is includable in her gross income.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference.
Petitioner resided in Red Bud, Illinois, when she filed her petition in this case. She timely filed her 1980 Federal income tax return with the Kansas City Service…
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