Goodwin v. United States

67 F.3d 149 (8th Cir. 1995)

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Nature of the Case

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Facts

P was a reverend at a church. From 1987 through 1989, P's annual salary from the Church was $7,800, $14,566 and $16,835; he also received a Church parsonage valued at $6,000 per year. In 1966, members of the congregation began making 'gifts' to P. Contributors purchased items such as furniture and works of art. Eventually, they began to give cash. Special occasion gifts were regularly solicited. The Church did not keep a record of the amount given nor who contributed to each gift. Ps did not report the special occasion gifts as taxable income. For the tax years 1987-1989, D estimated that Ps received $15,000 in 'special occasion gifts' each year. D then assessed deficiencies for the 1987-1989 tax years based upon the estimated unreported special occasion gifts. Ps paid the deficiencies and filed this refund suit. The established facts are that special occasion gifts were not required and all members of the Church deposed or interviewed maintained that the 'special occasion gifts' are gifts given to Ps out of love, respect, admiration and like impulses and are not given out of any sense of obligation or any sense of fear that P would leave the parish without more compensation. D got summary judgment, and P appealed.