Williams v. Comr., T.C. Sum Op. 2013-60

(ordained minister began employment with church in 2005 and employment agreement showed monthly housing allowance of $500 for six months with possibility of extension as approved by church; no extension executed; audit of minister's return revealed unreported income,  and lack of substantiation for business deductions, charitable contributions and additional expenses; during audit, petitioner amended return to reflect "unreported income" identified in part by audit and claimed that $33,126 of the corrected amounts constituted housing allowance; such amount adjusted on amended return as "returns and allowances"; second agreement (dated in 2012) executed after the date of audit specifying additional items identified as parsonage allowance, not allowed as a retroactive agreement; petitioner did not establish entitlement to parsonage allowance; accuracy related penalty assessed, due to inadequate records to substantiate expenses or income).