Legal Opinion

Toavs v. Commissioner

United States Tax Court

Decided March 7, 1977No. Docket Nos. 700-74, 2522-74, 2523-74, 2524-74, 2525-74, 2667-74, 2669-74, 3481-74, 3513-74Published

Petitioners, administrators of nursing homes, received amounts designated as parsonage allowances. Held: The amounts are not excludable from income despite the fact that petitioners are ordained ministers and operate the nursing homes under the "fellowship" of the Assemblies of God Church. Petitioners did not show any objective manifestation of control over the nursing homes by the Assemblies of God Church.

1Opinion of the Court

Jesse A. Toavs and Janice E. Toavs, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Toavs v. Commissioner

Docket Nos. 700-74, 2522-74, 2523-74, 2524-74, 2525-74, 2667-74, 2669-74, 3481-74, 3513-74

United States Tax Court

67 T.C. 897; 1977 U.S. Tax Ct. LEXIS 143;

March 7, 1977, Filed

Decisions will be entered for the respondent.

Petitioners, administrators of nursing homes, received amounts designated as parsonage allowances. Held: The amounts are not excludable from income despite the fact that petitioners are ordained ministers and operate the nursing homes under the…

2Cases cited3 opinions

  1. Colbert v. CommissionerUnited States Tax Court · 1974
  2. Tanenbaum v. CommissionerUnited States Tax Court · 1972
  3. Toavs v. CommissionerUnited States Tax Court · 1977

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