Legal Opinion

Mosley v. Commissioner

United States Tax Court

Decided September 14, 1994No. Docket Nos. 20269-92, 20270-92UnpublishedCited by 1 opinion

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

  1. Boyer v. CommissionerUnited States Tax Court · 1977
  2. Eden v. CommissionerUnited States Tax Court · 1964
  3. Colbert v. CommissionerUnited States Tax Court · 1974
  4. Ling v. United StatesDistrict Court, D. Minnesota · 1961
  5. Toavs v. CommissionerUnited States Tax Court · 1977

3Cited by1 opinion

  1. Freedom from Religion Foundation, Inc. v. LewDistrict Court, W.D. Wisconsin · 2013

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API