Ezel / IRS Rulings / 1035022
Chief Counsel Advice 1035022 Released September 3, 2010 Advice

CCA addressed self-employment tax treatment of a minister's compensation and parsonage allowance

Apply this to your situation

This page covers one taxpayer's ruling from 2010, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2010
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

The Office of Chief Counsel advised that if a minister has an exemption effective under IRC § 1402(e), compensation paid for ministerial services is exempt from self-employment tax. The advice states that designating part of that compensation as a parsonage allowance under IRC § 107, and whether the designated amount is ultimately excludable from income, does not affect the section 1402(e) exemption.

Ruling snapshot

  • Question: Does a minister's section 107 parsonage allowance designation affect an effective section 1402(e) exemption from self-employment tax?
  • Outcome: Advice given
  • Key authorities: IRC §§ 107 and 1402(e); IRC § 6110(k)(3) not-precedent notice

Full text (IRS public release)

ID: CCA_2010081111422869 Number: 201035022
Release Date: 9/3/2010
Office: ----------------------------
UILC: 1402.05-00

From: -----------------------
Sent: Wednesday, August 11, 2010 11:43:02 AM
To: --------------------
Cc:
Subject: RE: Question regarding section 1402

If a minister has an exemption effective under section 1402(e) compensation paid for ministerial services
is exempt from self-employment tax. The fact that a portion of this compensation was designated as a
parsonage allowance excludable for income tax purposes under section 107, and whether the entire
amount designated as such was ultimately excludable from income, would not affect the exemption under
section 1402(e).

Let me know if you have further questions.

----------------------------

--------------------------------------------------------------------------------------------------------------------------------------------

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2010, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.