Margaret Fuller4 360x1000
Margaret Fuller5 360x1000
Ruth Bader Ginsburg 360x1000
2jesusandjohnwayne
Margaret Fuller3 360x1000
3paradise
LillianFaderman
12albion
1empireofpain
10abion
3confidencegames
James Gould Cozzens 360x1000
2lookingforthegoodwar
Maurice B Foley 360x1000
399
2theleastofus
Learned Hand 360x1000
Samuel Johnson 360x1000
11albion
lifeinmiddlemarch1
AlexRosenberg
Mary Ann Evans 360x1000
Susie King Taylor2 360x1000
Margaret Fuller2 360x1000
2lafayette
Storyparadox1
1falsewitness
2gucci
1trap
14albion
1lookingforthegoodwar
2defense
Margaret Fuller 360x1000
Adam Gopnik 360x1000
George M Cohan and Lerarned Hand 360x1000
Tad Friend 360x1000
Spottswood William Robinson 360x1000
7albion
1paradide
Maria Popova 360x1000
1gucci
499
Betty Friedan 360x1000
4confidencegames
storyparadox2
5confidencegames
4albion
2paradise
Lafayette and Jefferson 360x1000
lifeinmiddlemarch2
Susie King Taylor 360x1000
1confidencegames
2transadentilist
3albion
1lafayette
George F Wil...360x1000
Mark V Holmes 360x1000
11632
9albion
1transcendentalist
7confidencegames
Stormy Daniels 360x1000
13albion
2trap
Thomas Piketty3 360x1000
1jesusandjohnwayne
Brendan Beehan 360x1000
Anthony McCann1 360x1000
Richard Posner 360x1000
Margaret Fuller1 360x1000
Anthony McCann2 360x1000
Thomas Piketty2 360x1000
1madoff
8albion'
storyparadox3
Thomas Piketty1 360x1000
5albion
1lauber
1albion
Margaret Fuller 2 360x1000
Office of Chief Counsel 360x1000
2albion
2confidencegames
Gilgamesh 360x1000
2falsewitness
299
1defense
3defense
3theleastofus
6confidencegames
1theleasofus
199
6albion
Edmund Burke 360x1000

Seventh Circuit Blesses Tax Free Housing Payments To Clergy

Although I will be studying the decision more, I think it is fair to say that the reasoning of Professor Edward Zelinsky author of Taxing The Church carried the day.  The Court viewed 107(2) as just one of a myriad of provisions exempting housing.  To treat ministers like secular employees receiving the 119(a) convenience of the employer exemption might lead to intrusive inquiries.  This is weighed against the IRS having to patrol the boundary of who is a minister.

These parallel provisions show an overarching arrangement in the tax code to exempt employer-provided housing for employees with certain job-related housing requirements. Congress has exempted certain categories of  employees from complying with the specific requirements of § 119(a)(2) to simplify the application of the convenience-of-the-employer doctrine to those occupations. Section 107, including subsection (2), recognizes ministers often use their homes as part of their ministry. This provision thus eases the administration of the convenience-of-the-employer doctrine by providing a bright-line rule, instead of requiring that ministers and the IRS repeatedly engage with a fact-intensive standard.

read more

Tax Court Petition: Just Go To The Post Office

Now the Endicia.com date stamp might have been good except for two things.  If there is a USPS date stamp on the envelope, that trumps anything else.  This envelope had the Endicia.com date of March 6, which was the absolute drop dead for mailing the petition.  There were two USPS date stamps.  One was March 7 and the other was March 20.  So Teri loses there.

The other requirement is that the petition actually arrive at the Tax Court in a normal amount of time, three days in this case.  This one arrived on March 26, twenty days, which probably would not have been good time even in pre-railroad days.

read more

Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.