Clergy Housing Calculator — FINAL verification pass (ship / no-ship gate)
- Reviewer: Fable 5.1 (independent; did not author the rules or the resolutions)
- Date: 2026-09-25
- Files verified (not edited):
sources/clergy-housing.yaml(29 rules)sources/clergy-housing-test-cases.yaml(45 cases)reviews/clergy-housing-2026-09-25-resolutions.md(45 prior findings: 36 FIXED, 9 REFER)- prior reviews:
-opus.md,-fable.md,-codex.md
VERDICT: PASS
No new substantive finding: no wrong number, no wrong eligibility, no missing clamp. Every FIXED
resolution was checked against the current primary source and holds. Every handling: refer rule is
the right call and its plain-language reason is accurate. Six minor wording nits are listed below;
one of them (N-1, T4 code 30) should be applied before any help text is written, because it is a
design trap rather than a rule error.
1. Primary sources opened this pass (14 fetches of 15)
| Source | How read | Result |
|---|---|---|
| T1223 E (25) PDF — https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/t1223/t1223-25e.pdf | Downloaded, text extracted locally (PyMuPDF), both pages | Footer "T1223 E (25)". Part C(B) has lines 1–10 exactly as quoted in CA-05. Notes 1–4, Part C(A), Part C(C), "Do not send this form … Keep it", "consolidated and archived Interpretation Bulletin IT-141R", CPP/QPP disability exclusion, and the un-numbered "How many months did you ordinarily occupy this residence" question all match the YAML excerpts verbatim. |
| CRA T1223 form page | WebFetch | Current version (25), page modified 2026-01-20; previous versions listed back to (02). |
| ITA s.8 — https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-8.html | Downloaded HTML via curl (WebFetch summariser refused verbatim), tags stripped | 8(1)(c)(i)–(iv) incl. "(to a maximum of ten)", "one-third", "the amount, if any, by which", "(other than an amount deducted under this paragraph by the taxpayer)", "to the extent that the amount can reasonably be considered to relate to the period"; 8(10) verbatim. All CA excerpts match. |
| CRA payroll page, clergy residence (modified 2026-01-16) | WebFetch ×2 | Step 4 both scenarios verbatim as in CA-11 (incl. the stale "line 11" reference, T1213, letter of authority). Non-cash: "EI (do not withhold unless cash earnings were also paid in the pay period)". Reporting: non-cash → Box 14, 26, Code 30; cash allowance → Box 14, 24, 26, Code 30; Code 40 for utilities when the deduction is not claimed. Worked example box 26 = $36,000 after a $17,000 authorized reduction. |
| CRA line 23100 page (modified 2026-01-20) | WebFetch | Eligibility bullets and "Keep all your documents" match CA-10 / CA-09. |
| TP-76-V (2016-10) PDF | Downloaded, text extracted locally | "you must be required to use the residence…"; "Enclose the form with your income tax return. If you had more than one employer … a separate form must be filed"; lines 1–13 verbatim (line 4 "maximum 10 months", line 9 "least" of 2/5/8, line 10 box V allowance, line 11 "greater" of 9/10 → line 207, line 12 = 1 + 11, line 13 = lesser of 2/12); Part 2 "You do not need to complete or sign this form if your employee was not required to use…". All CA-QC excerpts match. |
| IRS Pub 517 (2025) "For use in preparing 2025 Returns" | WebFetch ×2 | Designation, national-agency, informal-discussion, smallest-of (home ownership), rental allowances + reasonable pay, excess allowance → line 1h, parsonage incl. utilities + reasonable pay + "up to your actual cost", Rev. Baker ($24,000/$67,000/$7,500/$7,000 → $31,000/$60,000/$91,000), Pastor Adams ($39,000 + $12,000 = $51,000), retired ministers + surviving spouse, "substantially all … for social security purposes", minister of music sentence, teachers/administrators, home ownership Schedule A, allocation rule + exception + "not your SE tax". All US excerpts match. |
| Treas. Reg. §1.107-1 (a)–(c) | WebFetch | Duties test; "designated as rental allowance pursuant to official action taken in advance"; same-year rule; rent/purchase/directly-related; food and servants excluded; farm/business portion "shall not be excluded". Matches US-02/05/07 notes. |
| 26 U.S.C. §1402(a)(8) | WebFetch | Verbatim match to US-04/US-11. |
| Gaylor v. Mnuchin slip opinion (ca7 media server) | Downloaded PDF, text extracted locally | "Nos. 18-1277 & 18-1280 … ARGUED OCTOBER 24, 2018 — DECIDED MARCH 15, 2019 … BRENNAN, Circuit Judge … We conclude § 107(2) is constitutional. The judgment of the district court is REVERSED." Matches US-08. Reporter cite 919 F.3d 420 not re-fetched (CourtListener; budget) — relied on the resolutions file's check. |
| Pub 1828 (Rev. 8-2015) | Not re-opened | Corroboration only; prior Fable pass verified verbatim. |
| IT-141R | Not attempted | No rule depends on it (confirmed by grep of the YAML: referenced only as "T1223 refers readers to…"). |
2. Resolution-by-resolution check (all 36 FIXED + 9 REFER)
| Prior finding | Checked against | Holds? |
|---|---|---|
| O F-01 / F F-01 / CX-03 mixed-year base | T1223 (25) lines 1, 3, 6 + Note 1 + Part C(C); ITA (iv)(A)(I) | Yes. L1 full-year, L3 status months, only L6 period-limited. CA-TC-13 = 19,000.00 recomputed; the withdrawn method reproduces 16,166.67 (regression guard works). |
| O F-02 / F F-04 clergy couple → refer | T1223 Notes 2 and 4; ITA (iv)(B)(II) | Yes. CA-12 quotes both notes verbatim; refer reason accurate. |
| O F-03 / F F-10 QC required-use → refer | TP-76-V p.1 and Part 2 | Yes. Verbatim. |
| O F-04 / F F-14 principal residence | ITA (iv) | Yes. CA-13 + CA-TC-17 (blocked) + CA-TC-15 (spouse-owned). |
| O F-05 / F F-08 substantially-all | Pub 517 two sentences; Reg (a) | Yes. US-07 excerpt honestly carries "for social security purposes" and the housing-specific sentence. |
| O F-06 / F F-02 / F F-15 CPP/T1213/EI | Payroll page Step 4 + table | Yes. Both scenarios now correct; EI stated affirmatively; "line 11" flagged as stale (form ends at line 10 — confirmed). |
| O F-07 / F F-03 10-line form, canada.ca source | T1223 (25) | Yes. Every CA rule cites the canada.ca (25) PDF; CA-05 is L1–L10; all derivations renumbered; no "L11" remains. |
| O F-08 / F F-11 excess vs paid | Pub 517 "Excess rental allowance"; Reg (b) | Yes. ALLOW = MIN(PAID, DESIGNATED); excess = ALLOW − exclusion; line 1h. US-TC-13/14 recomputed. |
| O F-09 double-benefit → US-10 + US-12 | Pub 517 "Home ownership", "Expenses Allocable…" | Yes. NESE sentence gone; allocation rule is refer with accurate reason. |
| O F-10 / F F-06 Gaylor | ca7 slip opinion | Yes. No Supreme Court claim; holding quoted verbatim; dates/dockets/judge confirmed. |
| O F-11 / O F-12 / O F-14 QC lines, per-employer, currency | TP-76-V lines 9–13, p.1 | Yes. Documentation-only formula matches the form; line 11 uncapped; 1.2.3 added. |
| O F-13 / F F-18 cost list | Reg (c) (verbatim this pass) | Yes. Property tax/insurance/furnishings labelled "not itemized in source". |
| O F-15 / CX-01 negative line 8 | ITA "the amount, if any, by which" | Yes. L8 = MAX(0, L6 − L7); CA-TC-14 = 0.00; 20,000 random draws found no bound or monotonicity violation. |
| O F-16 / F F-05 8(10) | ITA 8(10) verbatim | Yes. Statutory gate; keep-vs-file tension stated. |
| O F-17 / F F-12 IT-141R | T1223 (25) | Yes. Only the form's reference remains. |
| O F-18 cash allowance in line 1 | Payroll table; T1223 Part C(A) | Yes (but see N-1: the same table also puts the cash allowance at code 30). |
| O F-19 / F F-17 utilities | Pub 517 | Yes. Baker example reproduced exactly (US-TC-15). |
| O F-20 / F F-07 retired → refer | Pub 517; §1402(a)(8) | Yes. |
| O F-21 Pub 1828 secondary | — | Yes. |
| O F-22 rounding | — | Yes. Exact arithmetic, final half-up; CA-TC-02 16,666.67 confirmed with Fraction arithmetic. |
| O F-23 Schedule A / principal split | Pub 517 | Yes. |
| F F-09 same-year, farm/business | Reg (c) verbatim | Yes. US-TC-19/20 recomputed. |
| F F-13 REM full-year | Note 1 | Yes. |
| F F-16 box 30 / code 30 | Payroll page | Yes as far as it goes — see N-1. |
| F F-19 label | — | Yes. |
| CX-02 reasonable pay | Pub 517 | Yes. Warning on every US case (reasonable_pay_warning_shown: true present on all 20 computed US cases). |
3. Cases recomputed (independent script, exact Fraction arithmetic, final half-up)
Script: scratchpad recompute.py — 79 checks, 78 match, 1 deliberate self-test mismatch (proves the checker can fail).
Canada (all 22 cases): CA-TC-01 12,000.00 · CA-TC-02 16,666.67 · CA-TC-03 10,000.00 · CA-TC-04 9,100.00 · CA-TC-05 14,000.00 · CA-TC-06 6,000.00 · CA-TC-07 0.00 · CA-TC-08 16,000.00 · CA-TC-09 federal 12,000.00 (QC refer) · CA-TC-10 10,000.00 · CA-TC-11 12,000.00 · CA-TC-12 13,600.00 (L2 18,333.33, L4 10,000 confirmed) · CA-TC-13 19,000.00 (old method 16,166.67 ≠) · CA-TC-14 0.00 · CA-TC-15 12,000.00 · CA-TC-16 refer (reviewer-only ordering: A 15,000 / B 0 confirmed) · CA-TC-17 blocked · CA-TC-18 blocked · CA-TC-19 not eligible · CA-TC-20 sweep {0:8,000, 1:8,000, 6:8,000, 9:9,000, 10:10,000, 11:10,000, 12:10,000}, non-decreasing · CA-TC-21 20,000 random (REM, RENT, OTHER, MONTHS) draws: 0 ≤ d ≤ L1, d ≤ L6, non-decreasing in REM and MONTHS, non-increasing in OTHER — 0 violations · CA-TC-22 months 13 / 6.5 / −1 rejected; rent −500 → 0.00.
United States (all 23 cases): US-TC-01 24,000/0 · US-TC-02 18,000/0 · US-TC-03 24,000/6,000 · US-TC-04 26,000/6,000 · US-TC-05 20,000 · US-TC-06 0 + 18,000 · US-TC-07 20,000/0, wages 40,000, SE 60,000 · US-TC-08 12,000 · US-TC-09 0 · US-TC-10 USED 28,000, excl 28,000 · US-TC-11 14,000/36,000 · US-TC-12 9,000 + 15,400 = 24,400 · US-TC-13 20,000/0 · US-TC-14 15,000/0, undesignated 5,000 · US-TC-15 31,000 / unused 500 / wages 60,000 / SE 91,000 (= Pub 517 Baker) · US-TC-16 SE 51,000 (= Pub 517 Adams) · US-TC-17 refer · US-TC-18 not eligible · US-TC-19 16,000/4,000 · US-TC-20 20,000/2,000 · US-TC-21 0/20,000 · US-TC-22 20,000 random draws: identity exclusion + excess = ALLOW, bounds — 0 violations · US-TC-23 refer.
4. Refer rules: is referral right, is the reason accurate?
| Rule | Right call? | Reason accurate? |
|---|---|---|
| CA-12 clergy couple | Yes. Deterministic on the form, but the ordering + "0 on line 7" + spousal interaction is exactly where a self-serve tool double-counts. Conservative and defensible. | Yes — matches Notes 2 and 4 verbatim; CA-TC-16 reason is plain and correct. |
| CA-QC-01 / CA-QC-02 Québec | Yes. Extra required-use gate, per-employer forms, uncapped line-11 "greater of" step, different months wording. | Yes — every element of the CA-TC-09 reason is on the TP-76-V face. Federal line 23100 still computed (correct: Québec residents file a T1). |
| US-09 reasonable pay | Yes as policy; there is no numeric test in Pub 517 or the Reg. | Yes. (Definitional nit N-5.) |
| US-11 retired | Yes. Designation comes from the pension plan; SECA carve-out differs. | Yes — Pub 517 + §1402(a)(8) quoted; surviving-spouse caveat correct. |
| US-12 expense allocation | Yes. Needs the full ministry-income denominator. | Yes — exception for mortgage interest / real-estate tax and "not your SE tax" both correct. |
5. Findings — all MINOR (wording); none changes a number or an eligibility outcome
N-1 (minor, apply before help text) — T4 code 30 is NOT unique to employer-provided housing.
CA-08 notes quote the payroll table for a cash housing allowance as "Box 14 … Box 24 … Box 26". The live page (2026-01-16) lists it as "Box 14, Box 24, Box 26, Code 30 – Housing or utilities" — i.e. a renting/owning pastor with a cash allowance will also see an amount at code 30. CA-04's excerpt (T1223 Part C(A)) is verbatim and correct, and the rules gate Case (A) on residence_type, so no number is wrong. But an implementer reading CA-04 + CA-08 could build "amount at code 30 ⇒ employer-provided ⇒ deduction_A = box 30", which for a renter with REM $24,000 and a $12,000 allowance would give $12,000 instead of the correct Case (B) $10,000. Fix: in CA-08 notes add "Code 30" to the cash-allowance reporting list; in CA-04 notes add: "An amount at code 30 does not by itself mean the employer provided the residence — the calculator must gate on whether the taxpayer rented/owned (Part C(A): 'complete (B) below even if you received a housing allowance')". Optionally mention Code 40 (utilities when the deduction is not claimed).
N-2 (minor) — CA-11 scenario 1 precondition incomplete. The page requires the employee to do both: complete Parts A and C and request Part B, and tell the employer in writing. The rule text mentions only the written notice. Add the first condition.
N-3 (minor) — CA-13 "accepts ONE principal residence" vs the note on sequential moves. Clarify: "one principal residence at a time; if you moved between two rented/owned principal residences, enter the total for both periods on line 6".
N-4 (minor) — CA-14 invariant scope. "For Case B: deduction ≤ L6" should read "for the Case (B) component"; in a mixed year the (A)+(B) total legitimately exceeds L6 (CA-TC-13: 19,000 > 12,000).
N-5 (minor) — US-09 handling: refer is really "always warn". The header defines refer as "detects … and sends the user to their accountant without computing a number". US-09 computes the number and warns. Either add a third handling value (warn) or say so in the header.
N-6 (minor) — CA-TC-19 message. "appointed to full-time administrative service" → "engaged exclusively in full-time administrative service by appointment of a religious order or denomination" (statute wording; "exclusively" is load-bearing).
Not re-verified this pass (no change recommended): Gaylor reporter cite 919 F.3d 420 (slip opinion confirms everything else); Pub 1828 p.22 wording (corroboration only).
6. Ship decision
PASS — ship. Apply N-1 before any help text or intake screen mentions box/code 30. N-2 to N-6 can ride the same edit.