Mosley v. Commissioner
United States Tax Court
Held: Services rendered by husband petitioners, ministers, to organization constituted performance of sacerdotal functions within meaning of secs. 1.107-1(a) and 1.1402(c)-5(b)(2)(ii), Income Tax Regs., such that parsonage rental allowances paid for 1989 and 1990 were excludable from gross income under sec. 107, I.R.C.Held, further, no exclusion for 1987 and 1988 for failure of employer to designate amounts as rental allowances pursuant to official action taken in advance of…
Read the full summary
Held: Services rendered by husband petitioners, ministers, to organization constituted performance of sacerdotal functions within meaning of secs. 1.107-1(a) and 1.1402(c)-5(b)(2)(ii), Income Tax Regs., such that parsonage rental allowances paid for 1989 and 1990 were excludable from gross income under sec. 107, I.R.C.Held, further, no exclusion for 1987 and 1988 for failure of employer to designate amounts as rental allowances pursuant to official action taken in advance of payment.
1Opinion of the Court
MAURICE A. AND JACQUELINE MOSLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; MAURICE J. AND BILLIE J. MOSLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mosley v. Commissioner
Docket Nos. 20269-92, 20270-92
United States Tax Court
T.C. Memo 1994-457; 1994 Tax Ct. Memo LEXIS 462; 68 T.C.M. (CCH) 708;
September 14, 1994, Filed
Decision will be entered under Rule 155.
Held: Services rendered by husband petitioners, ministers, to organization constituted performance of sacerdotal functions within meaning of secs. 1.107-1(a) and 1.1402(c)-5(b)(2)(ii), Income Tax Regs.,…
2Cases cited5 opinions
- Boyer v. CommissionerUnited States Tax Court · 1977
- Eden v. CommissionerUnited States Tax Court · 1964
- Colbert v. CommissionerUnited States Tax Court · 1974
- Ling v. United StatesDistrict Court, D. Minnesota · 1961
- Toavs v. CommissionerUnited States Tax Court · 1977
3Cited by1 opinion
- Freedom from Religion Foundation, Inc. v. LewDistrict Court, W.D. Wisconsin · 2013