The parsonage allowance in § 107(2) allows clergymen and clergywome to exclude from gross income any rental allowance paid to them as compensation, as long as that allowance is used to rent or buy a home. In a recent court case [Freedom From Religion Foundation, Inc. v. Lew, 2013–2 USTC {50600, 112 AFTR 2d 2013– 7103 (D.Ct. Wis., 2013)], a District Court judge in Wisconsin ruled that this exclusion from income was unconstitutional. What rationale underlies the judge’s conclusion that this benefit is unconstitutional?