Goodwin v. United States

Over 25 years, pastor Goodwin (plaintiff) grew his church from 25 to nearly 400 members, and he and his wife regularly received substantial payments — often roughly doubling his modest official salary — funded by anonymous individual church-member donations that church leaders collected several times a year through formal established procedures and paid out on behalf of the whole congregation. The parties stipulated the individual donors acted voluntarily and viewed their donations as gifts rather than as payment for Goodwin's services; the IRS nonetheless found the payments taxable, and the Goodwins paid the resulting deficiency and sued for a refund.