When Houses are Homes…and When They are Not

The Eleventh Circuit decision recently issued its decision in C.I.R. v. Driscoll, reversing the earlier Tax Court decision. The Eleventh Circuit decision holds that taxpayers may apply the parsonage allowance income exclusion under the I.R.C. Section 107(2) to a singular house, as opposed to multiple houses as stated in the early decision. In reaching its final determination, the Eleventh Circuit examined tax code cannons, dictionary meanings, comparable sections of the Tax Code, and legislative history. This decision may have further implications for tax exemptions and treatment for singular versus multiple residences.