The taxpayer was a facilities manager at a Pentecostal church who, in addition to his regular functions, was allowed to perform some duties normally performed by a minister such as performing baptisms, serving communion or praying and counselling when called upon.
The deduction was not available to him given that he was not a member of the clergy (there was no evidence that showed any formal recognition (akin to ordination) had taken place), he was not a regular minister (he was selected due to his occupational background and competence rather than any spiritual criteria other than his supporting the general principles and beliefs of the church), and he was not a member of a religious order (there being no evidence of self-sacrifice and dedication to the goals of the organization to the detriment of it own material well-being, or that his spiritual and moral discipline and regime was markedly stricter than that to which lay members of the church were expected to adhere).