January 4, 2010
In a partially redacted emailed advice, the IRS addressed whether a minister has properly documented the employer’s designation of rental property as a parsonage for purposes of the section 107 housing allowance deduction.
UILC: 107.01-00
Release Date: 12/24/2009
ID: CCA_2009102913585741
Office: * * *
From: * * *
Sent: Thursday, October 29, 2009 1:58:58 PM
To: * * *
Cc:
Subject: 107 designation
The designation must be in advance of the payment, so the date of this letter does not demonstrate that the university made the designation in advance of the payment as required. However, the taxpayer could argue that the letter memorialized an official action taken earlier, i.e. in advance of the payment. Of course, the TP has yet to show any such letter for the years at issue. We also note that the allowance must be limited to the rental value of the home.
Source: EO Tax Today, January 4, 2010
Source: EO Tax Today, January 4, 2010
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