Pixley v. Comm'r
United States Tax Court
H is an ordained Baptist minister. In this proceeding to collect Ps' unpaid 1992 and 1993 tax liabilities by levy, Ps submitted to R's Appeals Office an offer in compromise, claiming a "tithe to church" as part of their necessary living expenses. In evaluating Ps' ability to pay their outstanding tax liabilities, the Appeals officer declined to take these alleged tithing expenses into account.
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H is an ordained Baptist minister. In this proceeding to collect Ps' unpaid 1992 and 1993 tax liabilities by levy, Ps submitted to R's Appeals Office an offer in compromise, claiming a "tithe to church" as part of their necessary living expenses. In evaluating Ps' ability to pay their outstanding tax liabilities, the Appeals officer declined to take these alleged tithing expenses into account. Held: Under relevant provisions of the Internal Revenue Manual, tithes that a minister is required to pay as a condition of employment are allowable in determining ability to pay outstanding tax…
1Opinion of the Court
BRADLEY M. AND MONICA PIXLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pixley v. Comm'r
No. 7093-02L
United States Tax Court
123 T.C. 269; 2004 U.S. Tax Ct. LEXIS 41; 123 T.C. No. 15;
September 15, 2004, Filed
Commissioner's disallowance of tithing expenses in determining taxpayers' ability to pay liabilities sustained.
H is an ordained Baptist minister. In this proceeding to
collect Ps' unpaid 1992 and 1993 tax liabilities by levy, Ps
submitted to R's Appeals Office an offer in compromise, claiming
a "tithe to church" as part of their necessary living
expenses. In evaluating Ps'…
2Cases cited11 opinions
- Harris v. McRaeSupreme Court of the United States · 1980
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- Regan v. Taxation With Representation of WashingtonSupreme Court of the United States · 1983
- United States v. LeeSupreme Court of the United States · 1982
- Lunsford v. Comm'rUnited States Tax Court · 2001
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