Legal Opinion

Stephenson v. Commissioner

United States Tax Court

Decided December 13, 1982No. Docket No. 12543-80PublishedCited by 251 opinions

Held, P could not exclude wages and other amounts received on the theory that he was an agent of either a church he purportedly created or the parent church (the Life Science Church), which allegedly ordained him as a minister. Held, further, P was not entitled to any charitable contribution deductions and could not claim personal exemption deductions with respect to his wife and two children.

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Held, P could not exclude wages and other amounts received on the theory that he was an agent of either a church he purportedly created or the parent church (the Life Science Church), which allegedly ordained him as a minister. Held, further, P was not entitled to any charitable contribution deductions and could not claim personal exemption deductions with respect to his wife and two children. Held, further, P is liable for the sec. 6653(b), I.R.C. 1954, addition to the tax for both 1976 and 1977 and for the sec. 6654 addition for 1977.

1Opinion of the Court

OPINION

Whitaker, Judge:

Respondent determined the following deficiencies and additions to the tax for petitioner for the years 1976 and 1977:

_Additions to the tax_

Year Deficiency Sec. 6651(a)1 Sec. 6653(a) Sec. 6654

1976 $21,625.35 0 $1,081.27 0

1977 53,451.70 $13,362.92 2,672.59 $1,902

In the amended answer, respondent raises the claim that petitioner is liable for section 6653(b) additions to the tax for fraud during both the years in issue.

The primary issue for decision is whether petitioner is relieved from income tax liability for the years in issue because of his association with the Life…

2Cases cited10 opinions

  1. Gajewski v. CommissionerUnited States Tax Court · 1976
  2. Beaver v. CommissionerUnited States Tax Court · 1970
  3. Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
  4. Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
  5. Estate of Pittard v. CommissionerUnited States Tax Court · 1977

5 more not listed; retrieve them via the Exa API.

3Cited by251 opinions

  1. Rowlee v. CommissionerUnited States Tax Court · 1983
  2. Petzoldt v. CommissionerUnited States Tax Court · 1989
  3. Niedringhaus v. CommissionerUnited States Tax Court · 1992
  4. Parks v. CommissionerUnited States Tax Court · 1990
  5. John L. Stephenson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984

246 more not listed; retrieve them via the Exa API.

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